## Facts

- Enrique Parra Duenas was convicted by a Los Angeles County jury of first-degree murder of Los Angeles County Sheriff’s Deputy Michael Hoenig.
- On October 29, 1997, Duenas used methamphetamine at a house in South Gate, California; early the next morning he rode a bicycle on Long Beach Boulevard carrying a loaded .45-caliber pistol concealed in his waistband.
- Deputy Hoenig, acting on instructions to stop cyclists due to recent burglaries involving a bicycle getaway, attempted to stop Duenas, who refused and made a hostile statement while continuing to ride.
- Hoenig pursued Duenas in a patrol vehicle; the encounter ended in a shooting that killed Hoenig.
- The prosecution presented forensic and reconstruction evidence, including expert biomechanical testimony and a computer-generated animation illustrating the prosecution’s reconstruction of the shooting.
- The jury found true special circumstances that the murder was committed to avoid a lawful arrest and that Duenas knew or should have known the victim was a peace officer performing duties.
- The jury returned a death verdict; the trial court denied the statutory motion to modify and imposed a death sentence.

## Issues

1. Whether the trial court abused its discretion by admitting a prosecution computer animation as demonstrative evidence, on the theory it was speculative and risked giving the prosecution’s account an aura of scientific certainty.
2. Whether substantial evidence supported the special-circumstance findings that Duenas killed to avoid lawful arrest and knew or should have known the victim was a peace officer performing duties.
3. Whether other asserted guilt-phase and penalty-phase errors, individually or cumulatively, required reversal.

## Decision

- The California Supreme Court affirmed the conviction and death sentence on automatic appeal.
- The court held the trial court did not abuse its discretion in admitting the computer animation as a visual aid to illustrate expert opinions and other admitted evidence.
- The court held substantial evidence supported both special-circumstance findings.
- The court rejected the remaining guilt-phase and penalty-phase claims and found no cumulative prejudice warranting relief.

## Legal Principles

- Computer animations may be admitted as demonstrative evidence to help the jury understand expert testimony or other admitted evidence when the animation is a substantially accurate depiction of what it purports to illustrate.
- An animation need not be an exact recreation of events; assumptions and limits may be addressed through clarifying testimony, cross-examination, and argument.
- Limiting instructions that the animation is not a literal reenactment and is offered only to assist evaluation of the evidence reduce the risk of undue prejudice or juror confusion.
- Special-circumstance findings are reviewed for substantial evidence; the reviewing court considers whether the record supports a reasonable inference satisfying the statutory elements.

## Conclusion

The court upheld a capital conviction and death sentence, ruling that a computer-generated animation grounded in record evidence and used to illustrate expert testimony was properly admitted with appropriate cautionary explanations, and that the evidence was sufficient to sustain the peace-officer and avoid-arrest special circumstances.


People v. Duenas, 281 P.3d 887 (Cal. 2012)