Friday, August 10, 2001
State High Court Upholds Death Sentence in Riverside Robbery-Murder
By KENNETH OFGANG, Staff Writer/Appellate Courts
The state Supreme Court yesterday unanimously upheld the death sentence imposed on a Riverside man for the 1986 beating death of an elderly neighbor, which jurors found to have occurred in the course of a robbery and burglary.
The death sentence was proportional to Ronald Harold Seaton’s “moral culpability” for the death of Willis Jones, Justice Joyce L. Kennard wrote.
“Defendant, a career criminal with five prior felony convictions, brutally beat to death an aged, defenseless man so he could rob the victim of his meager possessions,” the justice said. “On these facts, the death sentence is not ‘grossly disproportionate to the defendant’s individual culpability’...nor is it ‘disproportionate to the defendant’s personal responsibility and moral guilt.’”
Seaton was convicted of killing Jones in the victim’s home. The retired auto mechanic was beaten, apparently with a hammer, and stabbed, and the house was ransacked.
Seaton was arrested at home by Riverside police after he was identified by the victim’s grandson, who had confronted him before he ran from the house. Officers seized bloodstained clothing from the residence.
The prosecution argued that Seaton either entered the house with the intent to rob Jones, or else beat him, then decided to rob him, then beat him again.
Seaton admitted killing Jones, but denied that he intended to rob him. He said he had gone to Jones’ house earlier, looking for his girlfriend, and found her naked and alone with Jones.
He later went back to the house to confront Jones, got into an argument with him, and killed him, he said. He ransacked the house afterwards, he said, because he panicked and decided to make it look as if a burglar killed Jones.
Seaton’s girlfriend testified that she worked occasionally as a prostitute. The sight of her naked with Jones enraged him, she said, because he didn’t know about her part-time profession.
The prosecution presented rebuttal testimony from a police officer who said the woman had given a taped statement in which she admitted that Seaton knew she was a prostitute and shared in the proceeds of her work.
In the penalty phase, the prosecutor presented evidence of Seaton’s criminal past, including convictions for robbery, larceny, burglary, and assault between 1964 and 1980.
On appeal, defense counsel argued that prosecutors committed misconduct by relying on the testimony of a pathologist, Dr. Dewitt Hunter, whose work had been criticized by members of the District Attorney’s Office. The claim was based, in part, on three internal memoranda which the office turned over to Seaton’s trial lawyer between the guilt and penalty phases.
Hunter testified, among other things, that Jones was attacked twice, once at the foot of his bed and once at the head of it. He added that Jones was likely alive at the time of the second attack.
Hunter said he believed this, in part, because postmortem blood wouldn’t necessarily clot. A defense expert disagreed, saying that blood flowing from a corpse definitely would clot.
Even if Hunter was incompetent generally or gave erroneous testimony, Kennard said, the prosecution didn’t engage in misconduct by calling him as a witness. The general rule is that cross-examination and rebuttal are the appropriate vehicles for attacking defects in an expert’s testimony, she said.
An exception might exist if the prosecution was aware of the defects before the witness was called, Kennard reasoned. But a prosecutor’s doubts about testimony given by his or her own witness, the justice added, “are not a form of impeaching evidence that must be disclosed.”
Kennard also rejected the contention that Seaton was prejudiced as a result of being shackled during trial. Riverside Superior Court Judge George Grover ordered the shackling, he explained after the trial, because of the seriousness of the crime and the fact that the courtroom door was near the public entrance to the courthouse.
The defendant, he noted, was given the choice of wearing a leg brace or an ankle cuff with a small chain. He chose the latter, which is more comfortable, even though it was more likely to be seen by jurors.
Kennard said the judge abused his discretion by ordering the shackling in the absence of specific evidence that Seaton needed to be restrained. But even if it is assumed that jurors saw the shackles, Seaton can’t claim prejudice that he could have avoided by choosing the leg brace, nor did he show that the jury’s verdict was affected, she said
The justice acknowledged that at least one federal case, from the Eleventh Circuit, seems to hold that a death sentence is reversible per se if the defendant is improperly shackled during the penalty phase and the jurors see the restraints. But that ruling isn’t law in California, and in any event shouldn’t apply if the defendant is given the option of a less-visible restraint and rejects it, she said.
The case is People v. Seaton, 01 S.O.S. 3991.
Copyright 2001, Metropolitan News Company