People v. Hart CA2/4

INTRODUCTION

Defendant Jerald Hart appeals from a judgment sentencing him to life without parole after a jury found him guilty of special circumstance first- degree murder. He contends: (1) the trial court erred by failing to exclude a recorded statement allegedly procured in violation of his Miranda1 rights; (2) the prosecutor and investigating detective violated the Racial Justice Act (RJA) by invoking racial stereotypes; (3) the coroner’s testimony about the victim’s injuries was inadmissible hearsay; and (4) admission of the coroner’s testimony violated his Sixth Amendment right to confrontation. Defendant also asks that we independently review the in camera record of the Pitchess2 hearing, and we have done so. We affirm the judgment.

FACTUAL BACKGROUND

I. Prosecution’s Evidence

On April 9, 1980, firefighters responded to C.B.’s home on Brighton Avenue in Los Angeles after smoke was reported coming from the roof. When firefighters entered the home, they found C.B. dead on her bedroom floor. She was 79 years old at the time. Her body “from the torso up was heavily burned, incinerated,” and “it was only her lower extremities that were recognizable and were relatively…