## Facts

- Lee Ann Thurman, a developmentally disabled woman in her mid-20s, was found dead in her Redding apartment on August 5, 1988, nude and partly covered by a blanket.
- The autopsy showed bruising, manual strangulation, eight or nine stab wounds (mostly to the chest), and a separate stab wound to the vagina inflicted after death; cause of death was multiple chest stab wounds with manual strangulation.
- The next morning, Raymond Edward Steele entered a Reno casino and told security he had killed a girl, said he needed a drink, and stated he had the knife and the victim’s identification.
- Security recovered a knife and a wallet from Steele; he also told a police officer he had killed a woman and asked to talk.
- In a police interview, Steele stated he picked up Thurman while hitchhiking, paid her for oral sex, went to her home, drank heavily, and then “snapped”; he expressed hostility toward women and admitted using the recovered knife.
- The prosecution introduced evidence of Steele’s prior murder conviction to prove a charged special circumstance and for limited purposes under California evidence law, with limiting instructions.

## Issues

1. Whether the evidence supported first degree murder findings, including deliberation and premeditation, given Steele’s claims of intoxication and psychological disturbance.
2. Whether admission of prior murder evidence was an abuse of discretion under Evidence Code §§ 1101(b) and 352, and whether limiting instructions adequately constrained the jury’s use of that evidence.
3. Whether guilt-phase instructions on other-crimes evidence and on mental-state evidence (including intoxication and the abolished diminished-capacity doctrine) were erroneous or misleading.
4. Whether penalty-phase admission of aggravating evidence (including details of the prior murder and other misconduct), prosecutor argument, and penalty instructions (including the statutory factor instructions) were improper or unconstitutional.
5. Whether California’s death penalty statute and special-circumstance scheme were unconstitutional under the Eighth and Fourteenth Amendments.
6. Whether cumulative error required reversal of the conviction or the death judgment.

## Decision

- The California Supreme Court affirmed the first degree murder conviction, weapon-use enhancement, prior-murder special circumstance finding, prior serious felony findings, and the death sentence.
- The court held the evidence supported intent and deliberation despite asserted intoxication and mental disturbance.
- The court found no abuse of discretion in admitting prior murder evidence and concluded the probative value was not substantially outweighed by undue prejudice.
- The court concluded the jury instructions, viewed as a whole, properly limited the use of other-crimes evidence and correctly stated the law governing mental-state evidence and voluntary intoxication.
- The court upheld the penalty-phase evidentiary rulings and the standard penalty instructions, and rejected claims of prosecutorial misconduct or prejudice.
- The court rejected constitutional challenges to California’s capital scheme and found no cumulative error.

## Legal Principles

- Evidence of mental disorder or voluntary intoxication may be considered on whether a defendant formed the required mental state, but California law does not recognize an affirmative diminished-capacity defense.
- Other-crimes evidence may be admitted for non-character purposes under Evidence Code § 1101(b) and is subject to exclusion under Evidence Code § 352 only when prejudice substantially outweighs probative value; appellate review is deferential to the trial court’s balancing.
- Jury instructions are evaluated as a whole; a claimed ambiguity warrants relief only if there is a reasonable likelihood the jury misunderstood or misapplied the law.
- In the penalty phase of a capital case, aggravating evidence authorized by statute may be admitted subject to the court’s discretion to control undue prejudice, and standard instructions on weighing aggravation and mitigation are generally constitutionally sufficient.
- Repeated constitutional challenges to California’s death penalty statute are rejected where controlled by settled state precedent upholding the scheme’s narrowing function and sentencing procedures.
- Cumulative-error relief requires a showing that multiple errors, considered together, prejudiced the outcome; absent prejudicial errors, cumulative error does not warrant reversal.

## Conclusion

The California Supreme Court affirmed Steele’s capital conviction and death sentence, holding that the evidence supported first degree murder, the trial court acted within its discretion in admitting prior murder evidence with limiting instructions, the jury was properly instructed on mental state and other-crimes evidence, the penalty phase was conducted without reversible error, and the state’s death penalty statute was constitutional as applied.


People v. Steele, 27 Cal. 4th 1230 (Cal. 2002)