The California Court of Appeal recently upheld the murder conviction of Steven Daniel Carrillo, affirming his life sentence without parole. Carrillo was found guilty of first-degree premeditated murder and attempted murder in a case that involved gang violence and racial animus. The court's decision, filed on June 30, 2026, and certified for partial publication on July 28, 2026, addresses significant issues regarding racial bias in the courtroom and the admissibility of evidence.
The case stems from a shooting that took place in October 2020, where Carrillo shot and killed Derrion Thomas and attempted to murder Isaiah S. Both victims were African American and not affiliated with any gangs. The shooting occurred at a Motel 6 in Riverside, California, where Carrillo, a member of the East Side Riva gang, confronted the victims. The court's ruling is significant as it touches on the intersection of gang violence, racial tensions, and the legal system.
Background
The People, represented by the state of California, charged Carrillo with first-degree murder and attempted murder. The jury found him guilty on both counts, along with several enhancements, including a special circumstance for committing a hate crime. Carrillo's defense claimed that the prosecution's gang expert violated the California Racial Justice Act (RJA) by using racially charged language and exhibiting bias against Carrillo due to his ethnicity.
The shooting incident involved a history of violence between the East Side Riva gang, which is predominantly Hispanic, and the 1200 Block gang, which is primarily African American. The two gangs had a longstanding feud that included racial animus, leading to violent confrontations. During the trial, evidence presented showed that Carrillo had a history of using derogatory language towards African Americans and that the shooting was motivated by this animosity.
The Ruling
The court ruled against Carrillo's claims, affirming the conviction and addressing the RJA allegations. The judges noted that Carrillo forfeited his RJA and due process claims by not raising them during the trial. The court stated, "Carrillo forfeited his RJA and due process claims by not raising them in the trial court." The ruling emphasized that the statements made by the gang expert were based on the historical context of racial violence in the area rather than an appeal to racial bias.
Additionally, the court addressed Carrillo's arguments regarding the admissibility of testimony about the honesty of one of the witnesses. The court concluded that any potential error in admitting this testimony was not prejudicial to Carrillo's case. The judges stated, "It is not reasonably probable that Carrillo would have obtained a more favorable result absent the challenged testimony."
Impact
This ruling has significant implications for future cases involving claims of racial bias in the criminal justice system. It reinforces the importance of raising such claims at the trial level to preserve them for appeal. The court's decision also highlights the complexities of gang-related cases where racial dynamics play a crucial role in both the events leading to the crime and the courtroom proceedings.
Furthermore, the ruling underscores the court's commitment to addressing racial justice issues while also recognizing the relevance of a defendant's background and the context of the crime. As such, this case may set a precedent for how courts handle similar claims in the future, particularly in gang-related violence cases.
What's Next
While Carrillo's conviction has been upheld, it is unclear whether he will pursue further appeals in higher courts. The ruling from the California Court of Appeal may serve as a reference point for other ongoing cases involving racial bias and gang violence.