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People v. Manson

Citations: 61 Cal. App. 3d 102; 132 Cal. Rptr. 265; 1976 Cal. App. LEXIS 1800Docket: Docket Nos. 22239, 24376

Court: California Court of Appeal; August 13, 1976; California; State Appellate Court

Narrative Opinion Summary

This case involves the appeal of Charles Manson, Patricia Krenwinkel, Susan Atkins, and Leslie Van Houten, who were convicted of multiple counts of murder and conspiracy related to the infamous Tate-La Bianca murders in 1969. The primary legal issues concern the admissibility of evidence, witness credibility, and the impact of extensive media coverage on the fairness of the trial. Initially sentenced to death, the appellants' penalties were commuted to life imprisonment following a Supreme Court decision invalidating the death penalty. The testimony of Linda Kasabian, granted immunity, was a central element, providing critical evidence linking the appellants to the crimes. Her testimony was challenged on grounds of credibility due to prior LSD use, but the court found no basis to disqualify her. The evidence presented at trial, including Manson's influence over his followers and their communal lifestyle, corroborated Kasabian's account. Despite significant media attention, the court determined that measures such as jury sequestration ensured a fair trial, rejecting assertions of presumed prejudice. Van Houten's conviction was reversed for retrial due to issues with legal representation following her attorney's disappearance, while the convictions of Manson, Krenwinkel, and Atkins were affirmed.

Legal Issues Addressed

Admissibility of Evidence of Prior Conduct

Application: Manson's prior statements and conduct were admissible to demonstrate his influence over the Family and intent to incite violence, supporting the prosecution's case.

Reasoning: The admissibility of this evidence was justified based on its tendency to establish Manson's influence over the Family and the likelihood of his inciting violent acts.

Competency and Credibility of a Witness with Drug Use

Application: Kasabian's history of LSD use did not disqualify her as a witness, as there was no evidence of influence during the relevant events or testimony.

Reasoning: The court found no grounds to disqualify her as a witness based on the Evidence Code.

Corroboration Requirement for Accomplice Testimony

Application: The court found sufficient corroborative evidence to support Kasabian's testimony against the appellants, including Manson's declarations and other independent admissions.

Reasoning: Corroborative evidence can vary widely based on case circumstances, as established in People v. Luker.

Credibility of Immunity-Testified Witness

Application: Kasabian's testimony, granted under immunity, was deemed credible as there was no evidence she was coerced into altering her statements for conviction.

Reasoning: Her immunity was solely dependent on her willingness to testify honestly about her knowledge of the Tate-La Bianca murders, making her testimony admissible.

Effective Assistance of Counsel

Application: The trial court's appointment of new counsel for Van Houten due to her attorney's disappearance did not violate her right to effective assistance, as the substitute attorney provided adequate representation.

Reasoning: The court ultimately concludes that the grounds for appeal regarding Van Houten are minimal, emphasizing that substance should take precedence over form in the justice system.

Right to a Fair Trial Amidst Media Coverage

Application: Despite extensive media coverage, the court found that sequestration measures and voir dire ensured a fair trial environment, rejecting claims of presumed prejudice.

Reasoning: The court maintained a controlled trial environment, issuing silence orders and conducting thorough voir dire procedures.