People v. Barrett

The victim was found dead in the cell he shared with the defendant at Calipatria State Prison. The defendant admitted to stabbing the victim but claimed self-defense, alleging the victim had a knife and intended to attack him. The prosecution argued that the defendant killed the victim because he believed teh victim was an informant. Evidence included the discovery of a weapon made from the cell’s desk, testimony from inmates, and the defendant’s history of violent behavior in prison. The court held that the defense’s introduction of evidence about the victim’s violent character opened the door for the prosecution to introduce evidence of the defendant’s violent character under Evidence Code section 1103. The court also upheld the constitutionality of the lying-in-wait special circumstance and the use of the defendant’s juvenile conviction, reasoning that these provisions sufficiently narrowed the class of death-eligible defendants and were consistent with Eighth Amendment principles.