People v. Roberts

2 Cal.4th 271 (1992)

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Nature of the Case

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Facts

Roberts (D) was charged with and found guilty of the murders of Charles Gardner, a fellow prison inmate, and Albert Patch, a corrections officer. Gardner was assaulted in prison by fellow inmates who inflicted 11 stab wounds on Gardner. Gardner grabbed a knife left on the floor and pursued his assailants and eventually plunged his knife into the chest of a prison guard, Albert Patch who died. Gardner died from his wounds also. D and another Menefield were blamed for the murder of Gardner. Evidence was introduced at trial regarding that scenario but was refuted by the fact that the testifying witnesses were inmates, lived in the same cell, and were given special benefits from the state for their testimony. D also entered evidence to show that the stabbings were not the proximate cause of the death of Gardner as incompetent medical care was to blame. The prosecution tried to blame the death of Albert on D and Menefield because Gardner pursued Menefield until they were stopped by guards and Gardner had lost so much blood that he became an unconscious agent of D. D introduced evidence that Gardner intended to stab Albert to extract revenge on his keepers and that when Albert was stabbed, Gardner was physically capable of thinking for himself. D was convicted and sentenced to death and appealed for the failure to give proximate cause instructions regarding the death of Gardner and the incompetent medical care given.