The Sleepy Lagoon Zoot Suit Trial

People v. Zammora (1944) 66 Cal.App.2d 166.  (Note: only Defendant Gus Zamora was named in the title of the Court of Appeal opinion, but because the court reporter misspelled his name, the caption incorrectly reads, “Zammora.”) 

Following the 1942 conviction of 12 young men for the murder of a man that attended the party near the Sleepy Lagoon quarry/swimming hole in East Los Angeles, the Court of Appeal reversed the convictions based on, among other grounds, insufficiency of the evidence and the inability of the defendants to consult with their attorneys during trial. 

“Just verdicts cannot be founded upon unreasonable inferences, speculation or suspicion, but must be grounded upon satisfactory evidence and reasonable inferences predicated thereon.”  (Zammora, p. 201.) “[O]ur examination of the record in this case convinces us that there is a complete lack of material and relevant evidence from which the jury could properly find or infer that appellants formed a conspiracy. . . . There is also a total lack of evidence to show that any of the [defendants] murdered Diaz.”  (Id. p. 202.)

“[I]t was impossible for counsel to leave their table, consult with their clients in another part of the courtroom, and at the same time protect the record and listen to the testimony being given. Likewise, it was not possible for the defendants to call matters to the attention of their counsel while witnesses were testifying, or call attention to claimed inaccuracies in the testimony or to suggest to counsel questions for cross-examination.”  (Zammora, p. 234.) “A basic part of a defendant’s right to counsel is that of consultation whenever necessary. To afford to the defendant the benefits of the foregoing clause of the Constitution, it is essential that [a defendant] should be allowed to consult with . . . counsel not only prior to the commencement of his trial, but during the actual progress thereof.”  (Ibid.) “That a joint trial of numerous defendants speeds the wheels of justice and provides not only an expeditious but a less burdensome method for disposing of criminal cases furnishes no valid argument for depriving a defendant charged with crime of his right to the effective and substantial aid of counsel at all stages of the proceeding. To do that . . . is not to proceed promptly in the calm spirit of regulated justice, but to go forward with the haste of the mob.”  (Zammora, p. 235.)

In the last paragraph of the court’s 71-page opinion, the court noted, “In appellants’ briefs filed herein, we note the charge that the prosecution of these defendants is the result of racial prejudice. This claim is without foundation and finds no support in the record. . . .”  (Zammora, pp. 237-238.) The note must be placed in the appropriate context of an appellate court determining that, based on the four corners of the record it was presented, it found no prejudice was shown. The court’s conclusion does not detract from the fact that it was demonstrated, by numerous studies and reports of the events, that discrimination and prejudice were heavily involved in the Sleepy Lagoon defendants’ prosecution. (See, e.g., Governor’s Citizen’s Committee Report on Los Angeles Riots (1943), discussing the cause of the riots that followed the convictions: “Any American citizen suspected of crime is entitled to be treated as an individual, to be indicted as such, and to be tried, both at law and in the forum of public opinion, on his merits or errors, regardless of race, color, creed, or the kind of clothes [worn]. [⁋] [⁋] In undertaking to deal with the cause of these outbreaks, the existence of race prejudice cannot be ignored”].) 

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