## Facts

- Todd Jesse Garton was convicted in Shasta County of first degree murder of his pregnant wife, Carole Garton, and her fetus, and of conspiracy to murder Carole and her fetus.
- Garton was also convicted of conspiring with others to murder Dean Noyes, who lived in Oregon and was the husband of Garton’s codefendant, Lynn Noyes.
- Evidence showed extensive planning discussions in California regarding killing Dean in Oregon, including multiple planning meetings, sharing access information, and attempted trips toward Oregon.
- The prosecution’s theory for Carole’s killing was that Garton arranged the murder for financial gain and to continue a relationship with Lynn.
- The jury found special circumstances, including multiple murders and murder for financial gain, and returned a death verdict.
- Garton’s appeal was automatic and raised, among other claims, territorial jurisdiction over the Dean-conspiracy count, evidentiary and instructional issues, and claims concerning courtroom procedures (wedding ring restriction; security screening practices).

## Issues

1. Whether California courts had territorial jurisdiction to prosecute a conspiracy to murder Dean Noyes where the intended killing was to occur in Oregon.
2. Whether prohibiting Garton from wearing a wedding ring during trial violated his constitutional rights or caused prejudice.
3. Whether allowing prosecution investigating officers to bypass courthouse metal detectors deprived Garton of a fair trial.
4. Whether admission of hearsay statements attributed to the county coroner regarding Carole’s body and cause of death required reversal.
5. Whether alleged instructional errors, denial of a motion for judgment of acquittal, or cumulative error required reversal of the remaining convictions or the death judgment.

## Decision

- The California Supreme Court reversed the conviction for conspiracy to murder Dean Noyes for lack of territorial jurisdiction.
- The Court affirmed the judgment in all other respects, including the murder convictions, the conspiracy related to Carole and her fetus, and the death sentence.
- Any error in restricting Garton from wearing a wedding ring was harmless.
- The trial court did not err in permitting investigating officers to bypass metal detectors.
- Any error related to the coroner hearsay was nonprejudicial; asserted instructional errors were harmless; the evidence supported denial of judgment of acquittal; and there was no cumulative error requiring reversal.

## Legal Principles

- Territorial jurisdiction in California criminal cases requires statutory authorization; planning or preparatory acts within California do not necessarily confer jurisdiction over a conspiracy charge when the charged object offense is to be completed wholly in another state and jurisdictional prerequisites are not satisfied.
- A conviction must be reversed when the trial court lacks territorial jurisdiction over the charged offense.
- Courtroom-management or appearance restrictions warrant relief only upon a showing of prejudicial error; minor restraints on presentation (such as a jewelry restriction) are subject to harmless-error analysis.
- Administrative security practices for courtroom entry do not violate due process absent a showing they created an unfair trial or conveyed an improper message to the jury.
- Evidentiary or instructional error in a capital case does not require reversal when harmless in light of the full record; cumulative error requires reversal only if the combined effect of actual errors undermines the fairness of the trial.

## Conclusion

The court held California lacked territorial jurisdiction to sustain the conviction for conspiracy to murder an Oregon resident in Oregon, requiring reversal of that count, but it otherwise affirmed the convictions and death judgment because the remaining claims showed no reversible prejudice.


People v. Garton, 4 Cal. 5th 485, 412 P.3d 315 (Cal. 2018)