In a split ruling, the California Supreme Court Thursday ordered a new hearing in juvenile court for a man who confessed to authorities that he murdered his mother and conspired to kill his stepfather at the family’s home in Lynwood and contemplated killing three other people in a manner derived from the horror film “Scream” when he was a teenager more than two decades ago.
The 4-3 ruling from the state’s highest court ruled that the case against Mario Salvador Padilla, who was 16 at the time of the killing and is now 40, will be sent back for a transfer hearing where a juvenile court judge is expected to consider various factors such as the defendant’s maturity, degree of criminal sophistication, prior delinquent history and whether he can be rehabilitated.
Padilla — whose case has been the subject of numerous appellate court filings — was initially sentenced to life in prison without the possibility of parole for the Jan. 13, 1998, stabbing death of his mother, Gina Lenore Castillo. He has subsequently been re-sentenced two other times to life without parole.
But the California Supreme Court’s majority, in a ruling penned by Justice Goodwin H. Liu, found that a measure enacted by the state’s voters in 2016 applies to his case.
“He must receive a transfer hearing in a juvenile court, where the court will decide whether criminal adjudication is appropriate for the murder of his mother and conspiracy to kill his stepfather,” Liu wrote on behalf of the majority. “Whatever potential that hearing may have for reducing his punishment (the non-final part of his judgment), it does not authorize or constitute relitigation of guilt.”
A dissenting opinion, written by Justice Carol A. Corrigan, noted that Padilla was charged in adult court in 1998 after a hearing in juvenile court in which he was determined “not fit to be dealt with under juvenile court law.”
The dissenting opinion contends that the majority’s retroactive application of the voter-approved Proposition 57 “would short-circuit procedures intended to evaluate whether a defendant in Padilla’s circumstance has successfully been rehabilitated or still presents a danger to public safety if released.”
“Instead, these balanced procedures would be replaced by a new juvenile transfer hearing wherein the juvenile court would be forced to determine, over 20 years after the fact, whether Padilla should have been treated as a juvenile in 1999,” Corrigan wrote in the dissenting opinion. “If it were to so conclude, the juvenile court could no longer assert jurisdiction over him. His immediate release would be required, regardless of any sign of rehabilitation or consideration of public safety. It seems highly unlikely that voters intended, by silence, to dispense with these carefully crafted procedures for the treatment of youth offenders facing LWOP (life without the possibility of parole) terms.”
In a 2017 ruling, a three-justice panel from California’s 2nd District Court of Appeal noted that Padilla initially denied involvement in his mother’s killing and subsequently told investigators that he and his 14-year-old cousin, Samuel Ramirez, had discussed killing his mother and stepfather for more than a month before she was killed.
“According to appellant, killing his parents was his idea. The idea arose from `frustration’ regarding his lack of freedom, as his parents did not `let [him] go out anywhere,” according to the 2017 ruling.
Padilla also acknowledged that he and Ramirez contemplated killing three other people, including two female schoolmates, in a manner derived from the horror movie “Scream,” the appellate court justices noted in the 2017 ruling.
The trial court judge barred any reference to the movie “Scream” or the sequel “Scream 2” during the trial. The prosecutor had to remove mention of the horror flicks in the boys’ audio-taped confessions, which were played for jurors, along with a recording of a 911 call Castillo placed immediately after her son stabbed her 45 times while her nephew held her on the ground.
A piggy bank that contained $150 in baptismal gifts for the woman’s 1-month-old daughter was missing from the bedroom Padilla shared with the infant.
Padilla was convicted of murder for his mother’s killing, along with conspiracy for the plot to kill his stepfather, Pedro Castillo, who uncharacteristically didn’t make it home for lunch that day.
Jurors also found true the special circumstance allegations of murder during the commission of a robbery and murder while lying in wait — the latter of which was subsequently dismissed by a state appeals court panel due to insufficient evidence.
Padilla’s cousin, Ramirez, was also convicted of the killing. He was sentenced to 25 years to life in state prison because of his age at the time of the crime.
It was not immediately clear how the Los Angeles County District Attorney’s Office would handle the case once it is sent back.
Just after being sworn into office in 2020, District Attorney George Gascón issued a directive that eliminated the option of trying juveniles as adults for serious crimes and vowed that his office would “immediately end the practice of sending youths to the adult court system.”
But the county’s top prosecutor — who is facing a potential recall effort — backed away from that directive in February after he conceded that a two-year term in juvenile custody “may not be adequate” for a transgender woman, Hannah Tubbs, for sexually assaulting a 10-year-old girl in the restroom of a Palmdale restaurant.
In a Feb. 18 memo to office staff, Gascón noted that “in exceptional circumstances, criminal jurisdiction may be appropriate for youth offenders” and that juveniles may be selectively transferred to the adult court system in the “most egregious cases that warrant a state prison commitment.”