The California Supreme Court affirmed a judgment of conviction and sentence of death as modified. The court held that the trial court lacked the authority to strike or dismiss a jury’s special circumstance finding.

Gang member and California Youth Authority parolee Ronald Mendoza was walking late at night with Johanna Flores and Joseph Cesena. A police car pulled up behind them. Mendoza was immediately concerned, because he was carrying an illegal handgun. Both Flores and Cesena encouraged Mendoza to run, but he declined.