The California Supreme Court affirmed a judgment of conviction. The court held that a the trial court did not err in denying a defendant’s motion for continuance pending the availability of legislative guidance on how to determine whether a defendant’s mental retardation renders him ineligible for execution.

In 1983, West Covina Police Officer Ken Wrede attempted to apprehend Michael Jackson after responding to a report about an intoxicated person in the area. An altercation ensued. Jackson grabbed Wrede’s shotgun from his patrol car and shot him in the head, killing him.