P. v. Reed
A jury convicted Thomas Deshawn Reed of murdering Evelyn Scott and found true the robbery and burglary special circumstances. The jury also convicted Reed of first degree residential robbery, first degree burglary, arson of an inhabited structure, unlawful driving or taking of a vehicle, and two counts of receiving stolen property. The trial court sentenced him to a total term of life in prison without the possibility of parole plus 12 years. Reed appeals, contending (1) he received ineffective assistance when defense counsel failed to request a mistrial, (2) the trial court improperly admitted evidence of prior uncharged crimes, (3) the trial court improperly instructed the jury regarding malice, and (4) the court failed to hold a posttrial hearing under People v. Marsden (1970) 2 Cal.3d 118 (Marsden).
We reject Reed's first three contentions, but find the trial court erred in not holding a Marsden hearing. Accordingly, we reverse the judgment with directions.
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