P. v. Carranco
After trial, a jury convicted defendant Jesse Carranco and codefendant Jacob Townley Hernandez ("Townley") of attempted deliberate and premeditated murder (Pen. Code, §§ 664, 187) for Townley's shooting of Javier Lazaro in Santa Cruz on February 17, 2006. This court reversed the judgments against both defendants, finding error in the superior court's refusal to permit trial counsel to show their clients a sealed declaration by a prosecution witness attesting to his own participation in an attempted murder, along with a sealed transcript of the witness's plea agreement proceeding. We held that the trial court had deprived defendants of their Sixth Amendment right to effective assistance of counsel by denying them access to these materials. The Supreme Court granted review. In Townley's case the holding that error had occurred was unchallenged by the People, and the high court expressed no opinion on this point. It did, however, reject this court's conclusion that the error was a structural defect subject to automatic reversal under Perry v. Leeke (1989) 488 U.S. 272. On the contrary, our Supreme Court held that an analysis of prejudice was required under the standard articulated in Strickland v. Washington (1984) 466 U.S. 668, and it accordingly remanded the case for that purpose. (People v. Hernandez (2012) 53 Cal.4th 1095.)
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