The cost of judicial second guessing is too high

In March 2012, 15‑year‑old Sierra LaMar was kidnapped on her way to school. Although her body has never been found, investigators located her phone in a field about a mile from home, and all of her belongings--including every item of clothing she was wearing that morning--next to a farm shed about two miles away. Substantial forensic evidence linked Antolin Garcia‑Torres to the crime: his DNA on her clothing, her DNA on his car door handle and gloves, and her hair on a rope in his trunk.

When questioned, Garcia-Torres said he did not know Sierra, and his only explanation for the presence of his DNA on her clothing was that he regularly masturbated in his car and threw tissues out the window. He admitted to being on her street at the time she went missing.

The investigation also revealed that, nearly three years earlier, Garcia‑Torres attempted to kidnap three women from grocery‑store parking lots. His fingerprint was found on a battery inside a stun gun used in one of the attacks. Each victim was a lone woman, approached without provocation, in locations familiar to him.

These four crimes were tried together--a constitutionally preferred practice in California designed to promote fairness, efficiency and consistency. After a nearly five‑month trial before a highly experienced judge, a jury convicted Garcia‑Torres on all counts.

Fourteen years after Sierra's abduction and murder, and nearly a decade after the convictions, the court of appeal reversed. Despite our California Constitution's explicit preference for joint trials, the panel ruled the trial court erred in allowing the charges to be tried together.

But this decision disregarded a foundational appellate rule: a trial court's ruling may only be overturned when it "exceeds all bounds of reason." Trial judges, who hear the evidence firsthand, are best positioned to evaluate admissibility, prejudice and fairness. This deferential standard is deeply imbedded in appellate review nationwide. 

The appellate panel made no effort to show why the trial court's reasons were irrational. It simply disagreed--and disagreement is not an abuse of discretion. This departure from the required standard threatens to destabilize how serious multi‑victim cases are tried across the state because prosecutors and judges rely on these standards when they make these difficult decisions. If left uncorrected, the consequences will be significant. 

The consequences are immediate and profound. Sierra's family has endured the loss of their daughter and must now endure a second trial. No legal doctrine can justify that burden. 

Beyond just this one case, the constitutional preference for joint trials is also at risk. When crimes are of the same type, as these unquestionably were, joint trials protect victims from having to testify multiple times and prevent the already‑strained court system from absorbing unnecessary duplicate proceedings. Jurors are fully capable of following limiting instructions, a principle reaffirmed for decades.

If the decision stands, prosecutors and judges will face enormous pressure to sever cases to avoid the threat of reversal years later. This "play‑it‑safe" approach would invert the constitutional structure, making severance the norm and joint trials the exception. That result is not only inefficient--it undermines the very constitutional preference our courts are sworn to uphold.

The ruling also risks eroding public trust. This case was not reversed for lack of evidence. In fact, the evidence was compelling: Garcia‑Torres previously attempted to kidnap three women in locations he knew well, with the clear goal of taking them elsewhere to commit further crimes. He did not steal anything, did not speak to his victims and did not know them. His actions were about controlling them.

Three years later, Sierra was abducted under strikingly similar circumstances. She, too, was alone, vulnerable and taken from an area known to him. For more than three decades, the California Supreme Court has recognized that when similar crimes are committed for similar reasons, evidence of earlier crimes can properly inform a jury about motive and intent. Indeed, the "least degree of similarity" is required for cross-admissibility in these situations.

The appellate court may not have seen the connection. But the legal question was not whether the panel agreed--it was whether no reasonable judge could. The panel never engaged that question and instead replaced reasoned deference with its own thoughts. That is not the standard the law permits. 

The experienced trial judge reasonably concluded that attempting to kidnap three other women, each alone and vulnerable, helps a jury understand the defendant's motives and intent when targeting a fourth. Even if the court of appeal had disagreed, it was required to find that no reasonable judge could reach that conclusion. It did not. Only the California Supreme Court can correct this error--an error that threatens both constitutional structure and confidence in the courts.

Reversal of this case is not only necessary for Sierra's family and the three other women the defendant targeted--it is essential for preserving public trust, constitutional fidelity and the integrity of our courts.