Photo via Pixabay
A state appeals court panel Monday reversed one of two murder convictions of a Signal Hill man who was sentenced to life in prison without the possibility of parole for a 1996 killing in Whittier and another slaying in Long Beach in 2007.
The three-justice panel from California’s 2nd District Court of Appeal reversed Jeffrey Keith Means’ 2014 second-degree murder conviction for the June 1996 bludgeoning death of 48-year-old Hal Dean Shaw.
The reversal was based on testimony by a supervisor about blood found on the defendant’s shoes. The panel found that it amounted to hearsay because the supervisor did not prepare the relevant reports.
“The extent to which witnesses may testify in criminal trials about the results of scientific testing that they did not personally perform is an issue that has vexed federal and state courts since the United States Supreme Court decided Crawford v. Washington … in 2004,” Justice Victoria Gerrard Chaney wrote in the opinion.
The panel found that Means, now 51, had the right to confront witnesses against him and that the lower court erred in allowing the reports and data about the shoes into evidence over the defense’s objection.
The supervising criminalist did not do his own analysis, but only testified to the contents of his subordinate’s reports, according to court documents.
Chaney cited People v. Leon, noting that issues regarding the right to confrontation may arise when an expert “simply recites portions of a report prepared by someone else, or when such a report is itself admitted into evidence.”
Means also appealed his first-degree murder conviction for the fatal stabbing of 67-year-old Ronald Henry in his Long Beach apartment, arguing that there was insufficient evidence of premediation.
The panel found “sufficient substantial evidence” to support the jury’s verdict and affirmed that conviction, for which Means is serving a life sentence without the possibility of parole.
–City News Service
>> Want to read more stories like this? Get our Free Daily Newsletters Here!