February 11, 2026
Court of Appeal of the State of California, Fifth Appellate District
The Rule of People v. Dixon is that grand jury proceeding transcripts and police reports containing witness statements are inadmissible at Penal Code section 1172.6 evidentiary hearings, under circumstances where the defendant had no opportunity to cross-examine witnesses and the documents constitute multiple levels of hearsay without applicable exceptions.
January 28, 2026
Court of Appeal, Second Appellate District, Division One
The Rule of **People v. Diaz** is that trial courts are not required to expressly state they have considered a defendant's youth when determining whether the defendant acted with express malice/intent to kill in section 1172.6 proceedings, under circumstances where the court is aware of the defendant's age and counsel argues youth as a mitigating factor but the court finds the defendant personally intended the victims' deaths.