ambiguous instruction (California) · Go Syfert
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ambiguous instruction in California

51 California opinions name it 3 courts 1939–2025 9 in the last five years

The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (33)

CaseFollowedCited
Estelle v. McGuiregreen
scotus · 1991 · cited in 18 California opinions naming this issue, 1996–2025
2 sentences

2024“In reviewing an ambiguous instruction, we inquire whether there is a reasonable likelihood that the jury misunderstood or misapplied the instruction in a manner that violates the Constitution.” (People v. Covarrubias (2016) 1 Cal.5th 838, 906 .) That review is de novo (People v. Posey (2004) 32 Cal.4th 193, 218 ), and “[i]t is well established that the instruction ‘may not be judged in artificial isolation,’ but must be considered in the context of the instructions as a whole and the trial record” (Estelle v. McGuire (1991) 502 U.S. 62, 72 (Estelle)).

2017Viewing the instructions as whole, then, the omission of the "mere presence" instruction created ambiguity as to whether merely being present constituted "conduct" as referenced in CALCRIM No. 1400. " '[I]n reviewing an ambiguous instruction ..., we inquire "whether there is a reasonable likelihood that the jury has applied the challenged instruction in a way" that violates the Constitution.' " ( Prettyman, supra, 14 Cal.4th at p. 272 , 58 Cal.Rptr.2d 827 , 926 P.2d 1013 , quoting Estelle v. McGuire (1991) 502 U.S. 62 , 72, 112 S.Ct. 475 , 116 L.Ed.2d 385 .) In a petition for rehearing, the At

818
Melvin Meffery Wade v. Arthur Calderon, Warden of San Quentin Attorney General of Californiagreen
ca9 · 1994 · cited in 3 California opinions naming this issue, 2014–2014
2 sentences

2014(Wade v. Calderon (9th Cir. 1994) 29 F.3d 1312, 1320-1321 [reasonable likelihood is the proper standard for determining the effect of an ambiguous instruction, but not where the instruction is unambiguous] [overruled on other grounds by Rohan ex rel.

2014(Wade v. Calderon (9th Cir. 1994) 29 F.3d 1312, 1320-1321 [reasonable likelihood is the proper standard for determining the effect of an ambiguous instruction, but not where the instruction is unambiguous] [overruled on other grounds by Rohan ex rel.

33
Stephen Ho v. Thomas L. Carey, Warden Attorney General of the State of Californiagreen
ca9 · 2003 · cited in 3 California opinions naming this issue, 2014–2014
2 sentences

2014Gates v. Woodford (2003) 334 F.3d 803, 815 ]; Ho v. Carey (9th Cir. 2003) 332 F.3d 587, 592 [court is not required to use the “reasonable likelihood” standard when jury instruction is not merely ambiguous, but flatly erroneous].) The United States Supreme Court set forth the reasonable likelihood standard in Boyde v. California (1990) 494 U.S. 370 .

2014Gates v. Woodford (2003) 334 F.3d 803, 815 ]; Ho v. Carey (9th Cir. 2003) 332 F.3d 587, 592 [court is not required to use the “reasonable likelihood” standard when jury instruction is not merely ambiguous, but flatly erroneous].) The United States Supreme Court set forth the reasonable likelihood standard in Boyde v. California (1990) 494 U.S. 370 .

33
People v. Covarrubiasgreen
cal · 2016 · cited in 5 California opinions naming this issue, 2020–2024
2 sentences

2024“In reviewing an ambiguous instruction, we inquire whether there is a reasonable likelihood that the jury misunderstood or misapplied the instruction in a manner that violates the Constitution.” (People v. Covarrubias (2016) 1 Cal.5th 838, 906 .) That review is de novo (People v. Posey (2004) 32 Cal.4th 193, 218 ), and “[i]t is well established that the instruction ‘may not be judged in artificial isolation,’ but must be considered in the context of the instructions as a whole and the trial record” (Estelle v. McGuire (1991) 502 U.S. 62, 72 (Estelle)).

2022“In reviewing an ambiguous instruction, we inquire whether there is a reasonable likelihood that the jury misunderstood or misapplied the instruction in a manner that violates the Constitution.” (People v. Covarrubias (2016) 1 Cal.5th 838, 906 (Covarrubias).) Here, it is obvious that something is missing from the sentence which comprises the last paragraph of the instruction. 29 This is particularly clear from the written instruction, reproduced above.

25
Middleton v. McNeilgreen
scotus · 2004 · cited in 4 California opinions naming this issue, 2013–2025
2 sentences

2016He relies on Estelle v. McGuire (1991) 502 U.S. 62, 72 , which states, “It is well established that [an] instruction ‘may not be judged in artificial isolation,’ but must be considered in the context of the instructions as a whole and the trial record. [Citation.] In addition, in reviewing an ambiguous instruction . . . , we inquire ‘whether there is a reasonable likelihood that the jury has applied the challenged instruction in a way’ that violates the Constitution.” (Accord, Middleton v. McNeil (2004) 541 U.S. 433, 437 .) Defendant contends the prosecutor made statements during closing argum

2013As with an ambiguous instruction, we ask whether there is a reasonable likelihood (Middleton v. McNeil (2004) 541 U.S. 433, 437 [ 158 L.Ed.2d 701 , 124 S.Ct. 1830 ]) the jury applied the instructions in a manner that deprived defendant of his constitutional rights.

24
People v. Clairgreen
cal · 1992 · cited in 2 California opinions naming this issue, 2013–2025
2 sentences

2013The proper focus for consideration of prior violent crimes in the penalty phase is on the facts of the defendant’s past actions as they reflect on his character, rather than on the labels to be assigned the past crimes . . . .” (Id. at p. 73.) Concerning the asserted ambiguity of the instruction, the United States Supreme Court has stated: “[I]n reviewing an ambiguous instruction ... we inquire ‘whether there is a reasonable likelihood that the jury has applied the challenged instruction in a way’ that violates the Constitution.” (Estelle v. McGuire (1991) 502 U.S. 62, 72 [ 116 L.Ed.2d 385 , 1

2013The proper focus for consideration of prior violent crimes in the penalty phase is on the facts of the defendant’s past actions as they reflect on his character, rather than on the labels to be assigned the past crimes . . . .” (Id. at p. 73.) Concerning the asserted ambiguity of the instruction, the United States Supreme Court has stated: “[I]n reviewing an ambiguous instruction ... we inquire ‘whether there is a reasonable likelihood that the jury has applied the challenged instruction in a way’ that violates the Constitution.” (Estelle v. McGuire (1991) 502 U.S. 62, 72 [ 116 L.Ed.2d 385 , 1

22
People v. Lewisgreen
cal · 2009 · cited in 2 California opinions naming this issue, 2013–2013
2 sentences

2013(Estelle v. McGuire (1991) 502 U.S. 62, 72 [ 116 L.Ed.2d 385 , 112 S.Ct. 475 ] [“in reviewing an ambiguous instruction . . . , we inquire ‘whether there is a reasonable likelihood that the jury *973 has applied the challenged instruction in a way’ that violates the Constitution”]; People v. Lewis (2009) 46 Cal.4th 1255, 1298 [ 96 Cal.Rptr.3d 512 , 210 P.3d 1119 ] [same].) Defendant’s argument is untenable.

2013(Estelle v. McGuire (1991) 502 U.S. 62, 72 [ 116 L.Ed.2d 385 , 112 S.Ct. 475 ] [“in reviewing an ambiguous instruction . . . , we inquire ‘whether there is a reasonable likelihood that the jury *973 has applied the challenged instruction in a way’ that violates the Constitution”]; People v. Lewis (2009) 46 Cal.4th 1255, 1298 [ 96 Cal.Rptr.3d 512 , 210 P.3d 1119 ] [same].) Defendant’s argument is untenable.

22
Boyde v. Californiagreen
scotus · 1990 · cited in 8 California opinions naming this issue, 1990–2023
2 sentences

2013The proper focus for consideration of prior violent crimes in the penalty phase is on the facts of the defendant‘s past actions as they reflect on his character, rather than on the labels to be assigned the past crimes . . . .‖ (Id. at p. 73.) Concerning the asserted ambiguity of the instruction, the United States Supreme Court has stated: ―[I]n reviewing an ambiguous instruction . . . we inquire ‗whether there is a reasonable likelihood that the jury has applied the challenged instruction in a way‘ that violates the constitution.‖ (Estelle v. McGuire (1991) 502 U.S. 62, 72 ; People v. Clair (

1996The United States Supreme Court has held that “in reviewing an ambiguous instruction . . . , we inquire ‘whether there is a reasonable likelihood that the jury has applied the challenged instruction in a way’ that violates the Constitution.” (Estelle v. McGuire (1991) 502 U.S. 62, 72 [ 116 L.Ed.2d 385, 399 , 112 S.Ct. 475 ], quoting Boyde v. California (1990) 494 U.S. 370, 380 [ 108 L.Ed.2d 316, 328-329 , 110 S.Ct. 1190 ]; see also People v. Avena (1996) 13 Cal.4th 394, 417 [ 53 Cal.Rptr.2d 301 , 916 P.2d 1000 ].) As we shall explain, here there is no “reasonable likelihood” that the jury misa

18
People v. Prettymanred
cal · 1996 · cited in 4 California opinions naming this issue, 2010–2017
2 sentences

2017Viewing the instructions as whole, then, the omission of the "mere presence" instruction created ambiguity as to whether merely being present constituted "conduct" as referenced in CALCRIM No. 1400. " '[I]n reviewing an ambiguous instruction ..., we inquire "whether there is a reasonable likelihood that the jury has applied the challenged instruction in a way" that violates the Constitution.' " ( Prettyman, supra, 14 Cal.4th at p. 272 , 58 Cal.Rptr.2d 827 , 926 P.2d 1013 , quoting Estelle v. McGuire (1991) 502 U.S. 62 , 72, 112 S.Ct. 475 , 116 L.Ed.2d 385 .) In a petition for rehearing, the At

2017Viewing the instructions as whole, then, the omission of the "mere presence" instruction created ambiguity as to whether merely being present constituted "conduct" as referenced in CALCRIM No. 1400. " '[I]n reviewing an ambiguous instruction ..., we inquire "whether there is a reasonable likelihood that the jury has applied the challenged instruction in a way" that violates the Constitution.' " ( Prettyman, supra, 14 Cal.4th at p. 272 , 58 Cal.Rptr.2d 827 , 926 P.2d 1013 , quoting Estelle v. McGuire (1991) 502 U.S. 62 , 72, 112 S.Ct. 475 , 116 L.Ed.2d 385 .) In a petition for rehearing, the At

14
People v. Poseygreen
cal · 2004 · cited in 3 California opinions naming this issue, 2020–2024
2 sentences

2024“In reviewing an ambiguous instruction, we inquire whether there is a reasonable likelihood that the jury misunderstood or misapplied the instruction in a manner that violates the Constitution.” (People v. Covarrubias (2016) 1 Cal.5th 838, 906 .) That review is de novo (People v. Posey (2004) 32 Cal.4th 193, 218 ), and “[i]t is well established that the instruction ‘may not be judged in artificial isolation,’ but must be considered in the context of the instructions as a whole and the trial record” (Estelle v. McGuire (1991) 502 U.S. 62, 72 (Estelle)).

2023(People v. Posey (2004) 32 Cal.4th 193, 218 .) “ ‘ “[I]n reviewing an ambiguous instruction . . . , we inquire ‘whether there is a reasonable likelihood that the jury applied the challenged instruction in a way’ that violates the Constitution.” ’ [Citations.]” (People v. Pettie (2017) 16 Cal.App.5th 23, 60 .) “ ‘When an appellate court addresses a claim of jury misinstruction, it must assess the instructions as a whole, viewing the challenged instruction in context with other instructions, in order to determine if there was a reasonable likelihood the jury applied the challenged instruction in

13
People v. Jenningsgreen
cal · 1991 · cited in 2 California opinions naming this issue, 2013–2013
2 sentences

2013For example, we explained in People v. Jennings (1991) 53 Cal.3d 334, 386 [ 279 Cal.Rptr. 780 , 807 P.2d 1009 ], that “[t]he plain meaning of these instructions merely informs the jury to reject unreasonable interpretations of the evidence and to give the defendant the benefit of any reasonable doubt.

2013For example, we explained in People v. Jennings (1991) 53 Cal.3d 334, 386 [ 279 Cal.Rptr. 780 , 807 P.2d 1009 ], that “[t]he plain meaning of these instructions merely informs the jury to reject unreasonable interpretations of the evidence and to give the defendant the benefit of any reasonable doubt.

12
People v. Mitchellgreen
cal · 2019 · cited in 1 California opinions naming this issue, 2025–2025
2 sentences

2025(Estelle v. McGuire (1991) 502 U.S. 62, 72 ; People v. Clair (1992) 2 Cal.4th 629, 663 [adopting that standard in California law].) “The challenged instruction is viewed ‘in the context of the instructions as a whole and the trial record . . . .’ ” ( Mitchell, supra, 7 Cal.5th at p. 579; see also Middleton v. McNeil (2004) 541 U.S. 433, 437 (per curiam) [review is of “the charge as a whole”].) When viewed in the broader context of the other instructions and the trial record, there is no reasonable likelihood the jury applied the instruction in the manner Santiago suggests.

2025(Estelle v. McGuire (1991) 502 U.S. 62, 72 ; People v. Clair (1992) 2 Cal.4th 629, 663 [adopting that standard in California law].) “The challenged instruction is viewed ‘in the context of the instructions as a whole and the trial record . . . .’ ” ( Mitchell, supra, 7 Cal.5th at p. 579; see also Middleton v. McNeil (2004) 541 U.S. 433, 437 (per curiam) [review is of “the charge as a whole”].) When viewed in the broader context of the other instructions and the trial record, there is no reasonable likelihood the jury applied the instruction in the manner Santiago suggests.

11
People v. Nelsongreen
cal · 2016 · cited in 1 California opinions naming this issue, 2020–2020
1 sentence

2020Generally, “[i]n reviewing an ambiguous instruction, we inquire whether there is a reasonable likelihood that the jury misunderstood or misapplied the instruction in a manner that violates the Constitution. [Citation.] ‘A single instruction is not viewed in isolation, and the ultimate decision on whether a specific jury instruction is correct and adequate is determined by consideration of the entire instructions given to the jury.’” (People v. Covarrubias, supra, 1 Cal.5th at p. 906 ; see People v. Nelson (2016) 1 Cal.5th 513, 544 .) The People contend that, because the unanimity instruction w

11
People v. Millsgreen
cal · 2012 · cited in 1 California opinions naming this issue, 2016–2016
11
People v. Livingstongreen
cal · 2012 · cited in 1 California opinions naming this issue, 2016–2016
11
People v. Pearsongreen
cal · 2013 · cited in 1 California opinions naming this issue, 2016–2016
11
People v. Lucasgreen
cal · 2014 · cited in 1 California opinions naming this issue, 2016–2016
11
People v. Younggreen
cal · 2005 · cited in 1 California opinions naming this issue, 2015–2015
11
People v. Jaspargreen
calctapp · 2002 · cited in 1 California opinions naming this issue, 2015–2015
11
People v. Rivasgreen
calctapp · 2013 · cited in 1 California opinions naming this issue, 2015–2015
11
People v. Valdezgreen
cal · 2012 · cited in 1 California opinions naming this issue, 2013–2013
11
Collins v. Youngbloodgreen
scotus · 1990 · cited in 1 California opinions naming this issue, 2001–2001
11
People v. Avenagreen
cal · 1996 · cited in 1 California opinions naming this issue, 1996–1996
11
Bale v. San Jose Police Departmentgreen
calctapp · 1984 · cited in 1 California opinions naming this issue, 1993–1993
11
People v. Superior Court (Douglass)green
cal · 1979 · cited in 1 California opinions naming this issue, 1993–1993
11
Crane v. State Farm Fire & Casualty Co.green
cal · 1971 · cited in 1 California opinions naming this issue, 1986–1986
11
People v. Easleygreen
cal · 1983 · cited in 1 California opinions naming this issue, 1985–1985
11
Lockett v. Ohiogreen
scotus · 1978 · cited in 1 California opinions naming this issue, 1985–1985
11
Woodson v. North Carolinagreen
scotus · 1976 · cited in 1 California opinions naming this issue, 1985–1985
11
Eddings v. Oklahomagreen
scotus · 1982 · cited in 1 California opinions naming this issue, 1985–1985
11
Mason v. Mercury Casualty Co.green
calctapp · 1976 · cited in 1 California opinions naming this issue, 1984–1984
11
Argonaut Insurance v. Transport Indemnity Co.green
cal · 1972 · cited in 1 California opinions naming this issue, 1977–1977
11
State Farm Mutual Automobile Insurance v. Jacobergreen
cal · 1973 · cited in 1 California opinions naming this issue, 1976–1976
11

Distinguished, questioned or overruled (1)

CaseNegativeCited
Boyde v. Californiagreen
scotus · 1990 · cited in 8 California opinions naming this issue, 1990–2023
2 sentences

2013The proper focus for consideration of prior violent crimes in the penalty phase is on the facts of the defendant‘s past actions as they reflect on his character, rather than on the labels to be assigned the past crimes . . . .‖ (Id. at p. 73.) Concerning the asserted ambiguity of the instruction, the United States Supreme Court has stated: ―[I]n reviewing an ambiguous instruction . . . we inquire ‗whether there is a reasonable likelihood that the jury has applied the challenged instruction in a way‘ that violates the constitution.‖ (Estelle v. McGuire (1991) 502 U.S. 62, 72 ; People v. Clair (

1996The United States Supreme Court has held that “in reviewing an ambiguous instruction . . . , we inquire ‘whether there is a reasonable likelihood that the jury has applied the challenged instruction in a way’ that violates the Constitution.” (Estelle v. McGuire (1991) 502 U.S. 62, 72 [ 116 L.Ed.2d 385, 399 , 112 S.Ct. 475 ], quoting Boyde v. California (1990) 494 U.S. 370, 380 [ 108 L.Ed.2d 316, 328-329 , 110 S.Ct. 1190 ]; see also People v. Avena (1996) 13 Cal.4th 394, 417 [ 53 Cal.Rptr.2d 301 , 916 P.2d 1000 ].) As we shall explain, here there is no “reasonable likelihood” that the jury misa

18

Also cited on this issue (29)

CaseCitedYears
Colleen Mary Rohan, Ex Rel. Oscar Gates v. Jeanne Woodford, Warden green
ca9 · 2003
2 sentences

2014Gates v. Woodford (2003) 334 F.3d 803, 815 ]; Ho v. Carey (9th Cir. 2003) 332 F.3d 587, 592 [court is not required to use the “reasonable likelihood” standard when jury instruction is not merely ambiguous, but flatly erroneous].) The United States Supreme Court set forth the reasonable likelihood standard in Boyde v. California (1990) 494 U.S. 370 .

2014Gates v. Woodford (2003) 334 F.3d 803, 815 ]; Ho v. Carey (9th Cir. 2003) 332 F.3d 587, 592 [court is not required to use the “reasonable likelihood” standard when jury instruction is not merely ambiguous, but flatly erroneous].) The United States Supreme Court set forth the reasonable likelihood standard in Boyde v. California (1990) 494 U.S. 370 .

32014–2014
People v. Pettie green
calctapp5d · 2017
2 sentences

2023(People v. Posey (2004) 32 Cal.4th 193, 218 .) “ ‘ “[I]n reviewing an ambiguous instruction . . . , we inquire ‘whether there is a reasonable likelihood that the jury applied the challenged instruction in a way’ that violates the Constitution.” ’ [Citations.]” (People v. Pettie (2017) 16 Cal.App.5th 23, 60 .) “ ‘When an appellate court addresses a claim of jury misinstruction, it must assess the instructions as a whole, viewing the challenged instruction in context with other instructions, in order to determine if there was a reasonable likelihood the jury applied the challenged instruction in

2020(People v. Pettie (2017) 16 Cal.App.5th 23, 60 .) The correctness of jury instructions is determined by looking at the context of the entire charge, not by considering only part of an instruction or a particular instruction in isolation.

22020–2023
People v. Prieto green
cal · 2003
2 sentences

2014Defendant is correct that an instructional error that affects defendant’s substantial rights may be reviewed on appeal despite the absence of an objection. (§ 1259; People v. Prieto (2003) 30 Cal.4th 226, 247 .) We will therefore address the merits of his instructional challenge. “[I]n reviewing an ambiguous instruction …, we inquire ‘whether there is a reasonable likelihood that the jury has applied the challenged instruction in a way’ that violates the Constitution. [Citation.]” (Estelle v. McGuire (1991) 502 U.S. 62, 72 , fn. omitted.) B.

2014Defendant is correct that an instructional error that affects defendant’s substantial rights may be reviewed on appeal despite the absence of an objection. (§ 1259; People v. Prieto (2003) 30 Cal.4th 226, 247 .) We will therefore address the merits of his instructional challenge. “[I]n reviewing an ambiguous instruction …, we inquire ‘whether there is a reasonable likelihood that the jury has applied the challenged instruction in a way’ that violates the Constitution. [Citation.]” (Estelle v. McGuire (1991) 502 U.S. 62, 72 , fn. omitted.) B.

22014–2014
Roddenberry v. Roddenberry green
calctapp · 1996
2 sentences

2013(Winet, supra, 4 Cal.App.4th at p. 1165 .) However, “[o]ur review of the trial court’s interpretation of the agreement is governed by the settled rule that where extrinsic evidence has been properly admitted as an aid to the interpretation of a contract and the evidence conflicts, a reasonable construction of the agreement by the trial court which is supported by substantial evidence will be upheld.” (In re Marriage of Fonstein (1976) 17 Cal.3d 738, 746-747 ; Roddenberry v. Roddenberry (1996) 44 Cal.App.4th 634, 651 .) Accordingly, we defer to the trial court’s construction if it was a reasona

2013(Id. at pp. 39-40.) On appeal, "[o]ur review of the trial court's interpretation of the agreement is governed by the settled rule that where extrinsic evidence has been properly admitted as an aid to the interpretation of a contract and the evidence conflicts, a reasonable 19 construction of the agreement by the trial court which is supported by substantial evidence will be upheld." (In re Marriage of Fonstein (1976) 17 Cal.3d 738, 746-747 ; Roddenberry v. Roddenberry (1996) 44 Cal.App.4th 634, 651 .) Accordingly, we defer to the trial court's construction if it was a reasonable construction o

22013–2013
In Re Marriage of Fonstein green
cal · 1976
2 sentences

2013(Winet, supra, 4 Cal.App.4th at p. 1165 .) However, “[o]ur review of the trial court’s interpretation of the agreement is governed by the settled rule that where extrinsic evidence has been properly admitted as an aid to the interpretation of a contract and the evidence conflicts, a reasonable construction of the agreement by the trial court which is supported by substantial evidence will be upheld.” (In re Marriage of Fonstein (1976) 17 Cal.3d 738, 746-747 ; Roddenberry v. Roddenberry (1996) 44 Cal.App.4th 634, 651 .) Accordingly, we defer to the trial court’s construction if it was a reasona

2013(Id. at pp. 39-40.) On appeal, "[o]ur review of the trial court's interpretation of the agreement is governed by the settled rule that where extrinsic evidence has been properly admitted as an aid to the interpretation of a contract and the evidence conflicts, a reasonable 19 construction of the agreement by the trial court which is supported by substantial evidence will be upheld." (In re Marriage of Fonstein (1976) 17 Cal.3d 738, 746-747 ; Roddenberry v. Roddenberry (1996) 44 Cal.App.4th 634, 651 .) Accordingly, we defer to the trial court's construction if it was a reasonable construction o

22013–2013
Commissioner v. Clark green
scotus · 1989
1 sentence

2025(C.I.R. v. Clark (1989) 489 U.S. 726, 739 .) But the EFAA’s language is clear— not ambiguous—and Advantage advocates for a rewriting of the statute—not a narrow construction.

12025–2025
People v. Letner and Tobin green
cal · 2010
1 sentence

2024The omission of this third alternative made the instruction ambiguous.” (Letner, supra, 50 Cal.4th at 180-181 , fn. omitted.) Thus, the trial court’s finding below that the jury instructions clearly required an intent to kill was in error.4 Based on the ambiguous instruction alone, we cannot conclude as a matter of law that the jury’s special circumstance true findings were necessarily predicated on a finding appellant was an aider and abettor with an intent to kill the victims.

12024–2024
Reynolds v. Bement green
cal · 2005
1 sentence

2023As an initial matter, the contention is forfeited. “ ‘It is well settled that arguments ... cannot be raised for the first time in a petition for rehearing.’ ” 7Whether such knowledge is an element of aiding and abetting a lying- in-wait murder is not before us, and we express no opinion on the matter. 14 (Reynolds v. Bement (2005) 36 Cal.4th 1075, 1092 , abrogated on another ground by Martinez v. Combs (2010) 49 Cal.4th 35 .) In any event, assuming the reasonable likelihood standard applies, it is met here. 8 “Although a defendant need not establish that the jury was more likely than not to h

12023–2023
People v. Gentile red
cal · 2020
1 sentence

2023(People v. Posey (2004) 32 Cal.4th 193, 218 .) “ ‘ “[I]n reviewing an ambiguous instruction . . . , we inquire ‘whether there is a reasonable likelihood that the jury applied the challenged instruction in a way’ that violates the Constitution.” ’ [Citations.]” (People v. Pettie (2017) 16 Cal.App.5th 23, 60 .) “ ‘When an appellate court addresses a claim of jury misinstruction, it must assess the instructions as a whole, viewing the challenged instruction in context with other instructions, in order to determine if there was a reasonable likelihood the jury applied the challenged instruction in

12023–2023
Martinez v. Combs green
cal · 2010
1 sentence

2023As an initial matter, the contention is forfeited. “ ‘It is well settled that arguments ... cannot be raised for the first time in a petition for rehearing.’ ” 7Whether such knowledge is an element of aiding and abetting a lying- in-wait murder is not before us, and we express no opinion on the matter. 14 (Reynolds v. Bement (2005) 36 Cal.4th 1075, 1092 , abrogated on another ground by Martinez v. Combs (2010) 49 Cal.4th 35 .) In any event, assuming the reasonable likelihood standard applies, it is met here. 8 “Although a defendant need not establish that the jury was more likely than not to h

12023–2023
People v. Navarette green
calctapp · 2016
1 sentence

2023(People v. Posey (2004) 32 Cal.4th 193, 218 .) “ ‘ “[I]n reviewing an ambiguous instruction . . . , we inquire ‘whether there is a reasonable likelihood that the jury applied the challenged instruction in a way’ that violates the Constitution.” ’ [Citations.]” (People v. Pettie (2017) 16 Cal.App.5th 23, 60 .) “ ‘When an appellate court addresses a claim of jury misinstruction, it must assess the instructions as a whole, viewing the challenged instruction in context with other instructions, in order to determine if there was a reasonable likelihood the jury applied the challenged instruction in

12023–2023
People v. Hajek and Vo green
cal · 2014
1 sentence

2023(People v. Posey (2004) 32 Cal.4th 193, 218 .) “ ‘ “[I]n reviewing an ambiguous instruction . . . , we inquire ‘whether there is a reasonable likelihood that the jury applied the challenged instruction in a way’ that violates the Constitution.” ’ [Citations.]” (People v. Pettie (2017) 16 Cal.App.5th 23, 60 .) “ ‘When an appellate court addresses a claim of jury misinstruction, it must assess the instructions as a whole, viewing the challenged instruction in context with other instructions, in order to determine if there was a reasonable likelihood the jury applied the challenged instruction in

12023–2023
Rose v. Clark green
scotus · 1986
1 sentence

2021(Rose v. Clark (1986) 478 U.S. 570, 580 .)13 Here, the trial court modified CALCRIM 375 to emphasize that evidence of the counts 1 through 5 offenses (those involving Ericka) proved by a preponderance of the evidence “is only one factor to consider along with all the other evidence.

12021–2021
Kalivas v. Barry Controls Corp. green
calctapp · 1996
2 sentences

2019This failure resulted in an ambiguous rule, placing counsel and litigants in peril, as demonstrated by the events in this matter. 20 49 Cal.App.4th 1152 , 57 Cal.Rptr.2d 200 , in the absence of a demonstrated history of litigation abuse, ‘[a]n order based upon a curable procedural defect [including failure to file a statement required by local rule], which effectively results in a judgment against a party, is an abuse of discretion.’ [Citation.]” (Elkins, supra, 41 Cal.4th at p. 1364 .) The California Supreme Court found in Elkins that the “trial court abused its discretion in sanctioning peti

2019This failure resulted in an ambiguous rule, placing counsel and litigants in peril, as demonstrated by the events in this matter. 20 49 Cal.App.4th 1152 , 57 Cal.Rptr.2d 200 , in the absence of a demonstrated history of litigation abuse, ‘[a]n order based upon a curable procedural defect [including failure to file a statement required by local rule], which effectively results in a judgment against a party, is an abuse of discretion.’ [Citation.]” (Elkins, supra, 41 Cal.4th at p. 1364 .) The California Supreme Court found in Elkins that the “trial court abused its discretion in sanctioning peti

12019–2019
Elkins v. Superior Court green
cal · 2007
1 sentence

2019This failure resulted in an ambiguous rule, placing counsel and litigants in peril, as demonstrated by the events in this matter. 20 49 Cal.App.4th 1152 , 57 Cal.Rptr.2d 200 , in the absence of a demonstrated history of litigation abuse, ‘[a]n order based upon a curable procedural defect [including failure to file a statement required by local rule], which effectively results in a judgment against a party, is an abuse of discretion.’ [Citation.]” (Elkins, supra, 41 Cal.4th at p. 1364 .) The California Supreme Court found in Elkins that the “trial court abused its discretion in sanctioning peti

12019–2019
People v. Perry green
calctapp · 1979
2 sentences

2017For this proposition, the Attorney General cites People v. Perry (1979) 100 Cal.App.3d 251 , 161 Cal.Rptr. 108 ( Perry ).

2017For this proposition, the Attorney General cites People v. Perry (1979) 100 Cal.App.3d 251 , 161 Cal.Rptr. 108 ( Perry ).

12017–2017
People v. Watson green
cal · 1956
2 sentences

2017Viewing the instructions as whole, then, the omission of the "mere presence" instruction created ambiguity as to whether merely being present constituted "conduct" as referenced in CALCRIM No. 1400. " '[I]n reviewing an ambiguous instruction ..., we inquire "whether there is a reasonable likelihood that the jury has applied the challenged instruction in a way" that violates the Constitution.' " ( Prettyman, supra, 14 Cal.4th at p. 272 , 58 Cal.Rptr.2d 827 , 926 P.2d 1013 , quoting Estelle v. McGuire (1991) 502 U.S. 62 , 72, 112 S.Ct. 475 , 116 L.Ed.2d 385 .) In a petition for rehearing, the At

2017Viewing the instructions as whole, then, the omission of the "mere presence" instruction created ambiguity as to whether merely being present constituted "conduct" as referenced in CALCRIM No. 1400. " '[I]n reviewing an ambiguous instruction ..., we inquire "whether there is a reasonable likelihood that the jury has applied the challenged instruction in a way" that violates the Constitution.' " ( Prettyman, supra, 14 Cal.4th at p. 272 , 58 Cal.Rptr.2d 827 , 926 P.2d 1013 , quoting Estelle v. McGuire (1991) 502 U.S. 62 , 72, 112 S.Ct. 475 , 116 L.Ed.2d 385 .) In a petition for rehearing, the At

12017–2017
People v. Iniguez green
calctapp · 2002
12015–2015
People v. Tuggles green
calctapp · 2009
12015–2015
Soule v. General Motors Corp. green
cal · 1994
12015–2015
Winet v. Price green
calctapp · 1992
12013–2013
People v. Reyes green
cal · 1998
12013–2013
People v. Burgener green
cal · 1986
12013–2013
Calder v. Bull green
scotus · 1798
12001–2001
Sovereign v. People green
calctapp · 1983
12001–2001
Chamberlin v. Smith green
calctapp · 1977
11986–1986
People v. Lanphear green
cal · 1984
11985–1985
State v. Hill green
kan · 1962
11984–1984
People v. Maughs green
calctapp · 1908
11939–1939

Statutes the citing opinions construe

CA § Cal. Penal Code § 187 (15) CA § Cal. Evidence Code § 352 (12) CA § Cal. Evidence Code § 353 (6) CA § Cal. Evidence Code § 1101 (5) CA § Cal. Evidence Code § 1200 (5) CA § Cal. Evidence Code § 1235 (3) CA § Cal. Evidence Code § 780 (3) CA § Cal. Evidence Code § 801 (3) CA § Cal. Government Code § 70373 (3) CA § Cal. Penal Code § 288.7 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 51 (1939–2025) NJ 18 (1953–2022) MD 13 (1958–2016) NH 12 (1985–2023) NM 10 (1986–2022) IL 10 (1904–2021) LA 10 (1933–2006) WA 9 (1997–2025) WI 8 (2003–2024) TX 8 (1981–2025) MO 8 (1960–2018) OH 7 (2000–2019) DC 6 (1981–2021) OR 5 (1968–2020) HI 5 (1950–2017) NY 5 (1985–2022) NC 5 (1990–2007) CO 5 (2000–2026) FL 5 (1991–2011) PA 5 (1930–2026) WV 4 (1925–2025) CT 3 (1989–2012) ME 3 (1981–2025) ID 3 (2009–2009) UT 2 (2000–2012) KY 2 (2022–2024) AZ 2 (1995–2014) DE 2 (2017–2024) VT 2 (2004–2011) KS 2 (1990–2016) SD 2 (2009–2009) TN 2 (1993–2016) GA 2 (1963–1996) MI 2 (1975–1991) MN 2 (2005–2016)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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