A Yolo County judge has declared a mistrial in the case against a former UC Davis student charged in the 2023 stabbing spree that killed two people and injured another.
The series of stabbings happened within the span of a week and shocked Davis, a normally quiet college town.
Carlos Reales Dominguez was charged in the murders of 50-year-old David Breaux and 20-year-old Karim Abou Najm, as well as the attempted murder of then 64-year-old Kimberlee Guillory, who was stabbed multiple times through the wall of her tent.
The jury found Dominguez not guilty on two counts of first degree murder, and deadlocked on all remaining counts including second degree murder.
The defense argued that Dominguez was in a psychotic state due to schizophrenia and the criminal trial was delayed as he underwent treatment at a state hospital to restore competency.
Insight Host Vicki Gonzalez spoke with McGeorge School of Law Professor Mike Vitiello who is an expert in criminal law. He broke down the verdicts reached in this trial.
This interview has been edited for length and clarity.
The jury deliberated for three weeks before a judge declared a mistrial. What stands out to you about this outcome?
I think it reflects a number of things, one of which was that the jury took its job very, very seriously in a very moving and complicated case. I didn't attend the trial. I read a lot about it. But I think the judge—who turns out to be a former student of mine—I think he did a really good job in allowing the case to be tried fully. So I think you had a conscientious jury, a very difficult case, and a good judge.
What made it difficult?
Well, it's emotionally impactful. I mean, just think about the families who lost loved ones.
In fact, I've mentioned to you in the past, I think the second murder took place right across the street from where I live, and in fact, my wife and I gave some money for the public art that they put up there in the memorial. And the arrest was made right around the corner from us. I see the father there on a regular basis, and his pain must be extraordinary.
And yet, the complicated feature is that if someone really is going through a schizophrenic break, they don't have the criminal mindset to make them guilty of the crime. So, you have all the harm—the social harm—horrible, horrible killings. And at the same time, you may not have anyone who's actually guilty of murder.
At question isn't whether Dominguez committed the stabbings, right? The defense wasn’t arguing that he didn’t do it. What was the defense’s strategy?
Well, the strategy was to follow the law, which was to say that if he did not have the mental element required for the crime, that he was not guilty of the crime. And there's a bit of an oversimplification, but typically a crime consists of an act, death of another, but it also requires a mental state.
And so it's possible that someone did the act necessary to kill another, but didn't have the mental state. And that was the testimony in this case.
The [defense] said, "Look, he was delusional." I think the prosecutor tried hard to show, "Well, you can be schizophrenic, you can be mentally ill, and you could still be conscious of what you were doing." But it seems like the jury rejected that.
Can a hung jury or even the not guilty verdict be challenged?
The not-guilty cannot, that's the double-jeopardy problem.
And the hung jury, you don't challenge the hung jury. What you do is you decide whether you're going to retry the case. And I don't know what the prosecutors are doing. I've read now a number of different accounts by some lawyers in town, some of them who are my former students. And they sort of point in different directions. This might be a time for the prosecution to try to get a guilty plea.
Usually when you have a hung jury, you tend to have more people who are voting to convict and some people are holding out to acquit.
And here you, at least according to the report in the Davis Enterprise, the votes to convict for second-degree murder and for the attempted murder were 9-3 and 8-4, suggesting that the vast majority of the people on the jury really favored acquittal.
So, this might be a time to spare everyone—the families—another trial, and then just to find a resolution through a guilty plea.
This trial took place two years after the deadly stabbing of Breaux and Najm and the attempted murder of Guillory. Is there justice for them and their families?
Well, justice is defined not just from the victim's perspective. There's no justice if we convict someone who doesn't have the mental capacity to commit a crime. Now, I don't know if Dominguez was entirely delusional, but certainly there was testimony.
Criminal justice is primarily about assessing blame. For example, if you trip over something and injure someone and it was a complete accident. Even if it hurts you, we don't blame the person. We say, "Okay, it was an accident." Here, if the person really didn't have the mental capacity to understand the nature of what he was doing, then he didn't do anything that we can blame.
This trial was delayed. Remind us what happened for Dominguez to be deemed competent to stand trial.
First of all, competency and insanity are different concepts. Insanity is a separate concept than competency.
Competency is whether or not a person can understand the nature of the proceedings and therefore can work with his attorney to provide a defense. And interestingly enough, early on in this case, everybody, including the prosecutors' office, recognized that Dominguez did not have competency to stand trial. He was still obviously delusional. So the delay really came about because of the initial determination of incompetency.
If you look at the pictures initially [of Dominguez] and then look at the pictures of mid-trial, obviously something happened that has brought him back to competency. So, that's still the cause of the long delay. You have to allow someone to provide a fair defense.
And having someone who can't really explain and help his attorney is not going to be justice.
Dominguez remains in custody and is due back in court on July 24. What is this hearing for?
I think what they're going to do is to determine whether or not when the case is going to be retried; What are they going to do? Will there be a new trial?
The new trial would again not be about first degree murder—that's already litigated—but whether they would have a trial on the hung jury charges. And that may or may not be the time when they would have already arranged a plea agreement.
