People v. Alcala

KENNARD, J.

I concur in the judgment. I disagree, however, with the majority’s reasoning and conclusions on two issues.

I.

The trial court ruled that because prosecution witness Dana Crappa was “unable ... to testify . . . because of then existing . . . mental illness or *811infirmity” (Evid. Code, § 240, subd. (a)(3)), she was “unavailable” to testify and therefore the prosecution could introduce transcripts of her testimony from an earlier trial in this case (Evid. Code, § 1291). In upholding the trial court’s ruling, the majority relies solely on Crappa’s testimony at a hearing that was held outside the jury’s presence to determine whether she should be declared unavailable. (Maj. opn., ante, at p. 780.)

In my view, however, Crappa’s testimony was insufficient to support the trial court’s finding that she was an “unavailable” witness. At the unavailability hearing, Crappa testified she could not remember anything connected with the case. This testimony shows only that Crappa’s memory was deficient. Standing alone, this testimony is insufficient to support a conclusion that Crappa suffered from a “mental illness or infirmity” under Evidence Code section 240, subdivision (a)(3).

The trial court, however, also heard testimony from Dr. Anthony Staiti, a psychiatrist at Kaiser Hospital, that he had seen Crappa on three occasions in May and June 1985, a year before the trial. Based on these visits and on reports of another psychiatrist who had examined Crappa, Dr. Staiti developed a “working diagnosis” that Crappa was suffering from “post traumatic stress disorder chronic delayed,” a disorder that may cause amnesia. Not surprisingly, in view of her professed loss of memory, Crappa did not explicitly describe to Dr. Staiti what it was that she could not remember. She did tell Dr. Staiti, however, that it involved a murder committed in 1979. That was the year of the killing in this case.

Based on the combined testimony of Crappa and Dr. Staiti, the trial court could reasonably conclude that Crappa was “unavailable” to testify because of a “mental illness or infirmity,” and that the prosecution could therefore use her prior recorded testimony against defendant.

II.

Unlike the majority, I am not convinced that the trial court acted within its discretion in excluding under Evidence Code section 352 the expert testimony of Dr. Ray London, a psychologist, that the tape recordings of the police interviews of prosecution witness Dana Crappa revealed the use of suggestive and manipulative psychological techniques that could have influenced her testimony. (Maj. opn., ante, at pp. 787-789.) Here, the trial court ruled that Crappa was an “unavailable” witness because of “mental illness or infirmity” (Evid. Code, § 240, subd. (a)(3)). Moreover, the tape recordings of the police interviews of Crappa show that long before she lost all memory of the events relevant to this case, she had trouble remembering precisely *812what she had observed at the murder scene, but that police questioning enabled her to reconstruct those events. Thus, in my view, Dr. London’s evidence was pertinent to the jury’s evaluation of the believability of Crappa’s former recorded testimony that placed defendant at the murder scene.

The trial court’s exclusion of Dr. London’s testimony did not prejudice defendant, however. The jury had ample opportunity to determine whether the police interviewers had indeed influenced Crappa’s testimony: the jury heard the taped interviews, and, in closing argument, defense counsel highlighted specific police comments in those tapes that might have been suggestive.