People v. Tyler CA1/4

BACKGROUND

At the conclusion of his third trial, Tyler was convicted of murder, auto theft, and firearm violations arising from an incident in 1992. Tyler, who was “grossly intoxicated on cocaine,” jumped out of a window while fleeing a drug deal gone bad. He landed on a car and hit his head; he believed a bullet

2 had grazed his head when the buyer in the drug transaction pulled out a gun and fired a shot. The buyer pursued the armed Tyler down the street, where Tyler encountered the victim, Louise Manigo. Manigo was leaving for work at her customary time of 4:30 a.m. Tyler attempted to take Manigo’s car at gunpoint to drive himself to the hospital. Manigo grabbed the gun and a struggle ensued. Tyler shot Manigo more than once in the chest or abdomen. She died shortly thereafter. Tyler drove Manigo’s car to one hospital, then panicked, and left. After getting lost and abandoning the car, the bleeding Tyler hitchhiked, obtained a ride from a truck, left the truck, and was ultimately arrested near a freeway. Trial evidence corroborated Tyler’s account of the drug deal, his flight therefrom, his struggle with Manigo, and his path to the arrest. At his 1994 sentencing, the trial…