## Facts

- Stevie Lamar Fields was paroled after serving a manslaughter sentence and, over the next three weeks, committed multiple violent felonies in Los Angeles County.
- A jury convicted Fields of first-degree murder of Rosemary C. with a robbery-murder special circumstance, and of additional crimes against other victims, including robbery, kidnapping for robbery, rape, forcible oral copulation, and assault with a deadly weapon.
- Fields pleaded not guilty by reason of insanity and presented psychiatric testimony diagnosing antisocial personality (psychopathy) and opining he could not conform his conduct to the law.
- On cross-examination, the defense expert conceded that if “mental disease” excluded abnormalities manifested only by repeated criminal or antisocial conduct, Fields would not qualify.
- The trial court instructed the jury consistent with that limiting definition; the jury found Fields sane and returned a death verdict under then-applicable California law.
- The trial court denied posttrial motions and imposed the death sentence; the case reached the California Supreme Court on automatic appeal.

## Issues

1. Whether excluding jurors who would automatically vote against the death penalty denied a representative jury at the guilt phase.
2. Whether a prospective juror who could not vote for death in this case, though possibly in another, could be excused for cause.
3. Whether the robbery-murder special circumstance applies when the victim is killed after the perpetrator has taken possession of the property.
4. Whether psychopathy/antisocial personality, manifested only by repeated criminal or antisocial conduct, can constitute legal insanity under California’s then-current insanity standard.

## Decision

- The court affirmed the convictions, the sanity finding, the robbery-murder special circumstance, and the death sentence.
- The court held that death-qualification of the guilt-phase jury by excluding jurors who would automatically refuse to impose death did not violate representativeness or impartial-jury requirements.
- The court held that a juror who could not vote for death in the case being tried could be excused for cause even if the juror might theoretically vote for death in some other case.
- The court held the robbery-murder special circumstance was satisfied because robbery continues until the perpetrator reaches a place of temporary safety; the killing occurred during the continuous transaction of the robbery.
- The court upheld the insanity instructions and related cross-examination, concluding that an antisocial/psychopathic personality shown only by repeated criminal or antisocial behavior did not, by itself, establish a qualifying “mental disease” for legal insanity.

## Legal Principles

- In a capital case, prospective jurors may be excluded for cause if their views on capital punishment would prevent or substantially impair performance of their duties, including the ability to consider both life and death penalties in the case at hand.
- Excluding jurors who would automatically vote against death does not, by itself, render the guilt-phase jury unconstitutional.
- For robbery-murder special-circumstance purposes, a robbery is not complete until the perpetrator reaches a place of temporary safety; a homicide committed before that point may occur “during the commission” of the robbery even if the taking preceded the killing.
- Under California’s then-governing insanity framework, an abnormality manifested only by repeated criminal or antisocial conduct is not treated as a “mental disease or defect” for insanity; the jury may be instructed accordingly without directing a sanity verdict.

## Conclusion

The California Supreme Court upheld Fields’s guilt and penalty judgments, approving death-qualification based on jurors’ inability to consider death in the case, applying a continuous-transaction approach to the robbery-murder special circumstance, and sustaining insanity instructions that excluded antisocial conduct alone from the definition of qualifying mental disease.


People v. Fields, 35 Cal. 3d 329, 673 P.2d 680 (Cal. 1983)