People v. Boyd CA2/4

BACKGROUND

I. Underlying Crimes2

In the early morning hours of September 29, 1991, firefighters responded to a call about a car fully engulfed in flames. After the fire was extinguished, the naked body of a young woman was found inside, burned beyond recognition. She was covered in a blood-stained white t-shirt, and there was a

1 All further statutory references are to the Penal Code unless otherwise indicated. 2 The underlying facts are discussed in detail in this court’s prior nonpublished opinion, People v. Boyd (Oct. 7, 2019, B288876). We briefly summarize them here to provide context for the trial court’s ruling. We otherwise do not rely on this factual background in resolving the issues presented in this appeal. (See § 1172.6, subd. (d)(3).)

2 burned matchbook between her legs. The woman ultimately was identified through dental records as Jill S. An autopsy revealed contusions on Jill’s left arm and an extensive subdural hematoma on top of her head. Swabs were taken from her vagina and rectum. There was no soot in Jill’s airway, and the level of carbon dioxide in her blood was also consistent with death prior to the burn injuries. However, it was also…