A teenaged murder defendant who confessed his crime to a youth minister should have had no expectation that his confession would remain confidential, an appellate court has ruled in a notorious Bakersfield case. The ruling upheld the murder convictions and sentences of both young killers.
Kyle Hoffman and Luis Palafox were convicted of two counts of first-degree murder each for the 2008 deaths of 81-year-old Joseph Parrott and his 77-year-old wife, Dorothy, although Hoffman said he did not participate in killings.
Hoffman and Palafox were both 16 years old when the killings occurred and were each sentenced to consecutive terms of life in prison without the possibility of parole in 2010.
A major break in the case came when Hoffman confessed the crime to his next door neighbor, youth minister Reginald Cotton, who in turn alerted police.
In the appeal, Hoffman argued that things he told Cotton should have been kept out of his trial based on "clergy-penitent privileges," the court's opinion said. The appellate court struck down that argument, writing that there was no evidence that Cotton was authorized to receive confidential confessions or obligated keep what he was told a secret.
The 5th Appellate District of California ruling upheld the convictions of Hoffman and Palafox in the deaths of the southwest Bakersfield couple as well as their sentences of life without parole. The court rejected most elements of the appeal.
The court, however, struck down "parole revocation restitution fines" in their cases, according to an opinion posted on the court's website Thursday.
The court denied other arguments Hoffman made, including that he did not knowingly wave his Miranda rights when interviewed by police. The Miranda warning is intended to protect the suspect's right to refuse to answer self-incriminating questions.
The appellate court sided against Hoffman and Palafox's claim that sentencing a juvenile to life without parole goes against federal and state Constitutions, the opinion said. The court also disagreed with Hoffman's claim that the sentence was "disproportionate" for his role in the crime and therefore amounted to cruel and unusual punishment.