The Law of Innocence

Book 6: A Lincoln Lawyer Novel

by Michael Connelly

Genres: Police Procedurals; International Crime & Mystery; Crime Fiction; Thrillers; Legal Thrillers

Synopsis

Lincoln Lawyer Mickey Haller is back in the heartstopping new thriller from #1 New York Times bestselling author Michael Connelly.

Defense attorney Mickey Haller is pulled over by police, who find the body of a client in the trunk of his Lincoln. Haller is charged with murder and can’t make the exorbitant $5 million bail slapped on him by a vindictive judge.

Mickey elects to defend himself and must strategize and build his defense from his jail cell in the Twin Towers Correctional Center in downtown Los Angeles, all the while looking over his shoulder—as an officer of the court he is an instant target.

Mickey knows he’s been framed. Now, with the help of his trusted team, he has to figure out who has plotted to destroy his life and why. Then he has to go before a judge and jury and prove his innocence.

Release date: November 10, 2020

Publisher: Little, Brown and Company

Print pages: 400

Sample

Chapter 1

Monday, October 28

It had been a good day for the defense. I had walked a man right out of the courtroom. I had turned a felony battery charge into a righteous case of self-defense in front of the jury. The so-called victim had a history of violence of his own that both prosecution and defense witnesses, including an ex-wife, were eager to describe on cross-examination. I delivered the knockout punch when I recalled him to the witness stand and led him down a path of questioning that put him over the edge. He lost his cool and threatened me, said he’d like to meet me out in the street, where it would be just him and me.

“Would you then claim I attacked you, like you have with the defendant in this case?” I asked.

The prosecutor objected and the judge sustained. But that was all it took. The judge knew it. The prosecutor knew it. Everybody in the courtroom knew it. I notched the NG after less than half an hour of jury deliberation. It wasn’t my quickest verdict ever, but it came close.

Within the informal downtown defense bar, there is a sacred duty to celebrate a not-guilty verdict the way a golfer celebrates a hole in one at the clubhouse. That is, drinks all around. My celebration took place at the Redwood on Second Street, just a few blocks from the civic center, where there were no fewer than three courthouses to draw celebrants from. The Redwood was no country club but it was convenient. The party—meaning the open bar—started early and ended late, and when Moira, the heavily tattooed bartender who had been keeping the tab, handed me the damage, let’s just say I put more on my credit card than I would ever see from the client I had just set free.

I had parked in a lot on Broadway. I got behind the wheel, took a left out of the lot and then another to put me back on Second Street. The traffic lights were with me and I followed the street into the tunnel that went under Bunker Hill. I was halfway through when I saw the reflection of blue lights on the tunnel’s exhaust-smoked green tiles. I checked the mirror and saw an LAPD cruiser behind me. I hit the blinker and pulled into the slow lane to let him pass. But the cruiser followed my lead into the same lane and came up six feet behind me. I got the picture then. I was being pulled over.

I waited until I was out of the tunnel and took a right onto Figueroa. I pulled to a stop, killed the engine, and lowered the window. In the Lincoln’s side-view mirror a uniformed officer was walking up to my door. I saw no one else in the patrol car behind him. The officer approaching me was working alone.

“Can I see your license, car registration, and proof of insurance, sir?” he asked.

I turned to look at him. His name tag said Milton.

“You sure can, Officer Milton,” I said. “But can I ask why you pulled me over? I know I wasn’t speeding and all the lights were green.”

“License,” Milton said. “Registration. Insurance.”

“Well, I guess you’ll eventually tell me. My license is in my pocket inside my coat. The other stuff is in the glove box. Which do you want me to go for first?”

“Let’s start with your license.”

“You got it.”

As I pulled my wallet and worked the license out of one of its slots, I reviewed my situation and wondered if Milton had been watching the Redwood for lawyers exiting my party and possibly too tipsy to drive. There had been rumors about patrol cops doing that on nights when there was an NG celebration going on, and defense lawyers could be picked off for a variety of moving vehicle violations.

I handed Milton my license and then went for the glove box. Soon enough the officer had all he had asked for.

“Now are you going to tell me what this is about?” I asked. “I know I didn’t—”

“Step out of the car, sir,” Milton said.

“Oh, come on, man. Really?”

“Please step out of the car.”

“Whatever.”

I threw the door open, aggressively forcing Milton to take a step back, and got out.

“Just so you know,” I said. “I spent the last four hours in the Redwood but I didn’t have a drop of alcohol. I haven’t had a drink in more than five years.”

“Good for you. Please step to the back of your vehicle.”

“Make sure your car camera is on, because this is going to be embarrassing.”

I walked past him to the back of the Lincoln and stepped into the lights of the patrol car behind it.

“You want me to walk a line?” I said. “Count backward, touch my nose with my finger, what? I’m a lawyer. I know all the games and this one is bullshit.”

Milton followed me to the back of the car. He was tall and lean, white, with a high and tight haircut. I saw the Metro Division badge on his shoulder and four chevrons on his long sleeves. I knew they gave them out for five years of service each. He was a veteran Metro bullethead all the way.

“You see why I stopped you, sir?” he said. “Your car has no plate.”

I looked down at the rear bumper of the Lincoln. There was no license plate.

“Goddamn it,” I said. “Uh…this is some kind of a prank. We were celebrating—I won a case today and walked my client. The plate says IWALKEM and one of those guys must’ve thought it was a joke to steal the plate.”

I tried to think about who had left the Redwood before I did, and who would have thought this was a funny thing to do. Daly, Mills, Bernardo…it could have been anyone.

“Check the trunk,” Milton said. “Maybe it’s in there.”

“No, they would need a key to put it in the trunk,” I said. “I’m going to make a call, see if I can—”

“Sir, you’re not making a call until we’re finished here.”

“That’s bullshit. I know the law. I’m not in custody—I can make a call.”

I paused there to see if Milton had any further challenge. I noticed the camera on his chest.

“My phone’s in the car,” I said.

I started moving back to the open door.

“Sir, stop right there,” Milton said from behind me.

I turned around.

“What?”

He snapped on a flashlight and pointed the beam down at the ground behind the car.

“Is that blood?” he asked.

I stepped back and looked down at the cracked asphalt. The officer’s light was centered on a blotch of liquid beneath the bumper of my car. It was dark maroon at the center and almost translucent at its edges.

“I don’t know,” I said. “But whatever it is, it was already there. I’m—”

Just as I said it, we both saw another drop come down from the bumper and hit the asphalt.

“Sir, open the trunk, please,” Milton demanded as he put the flashlight into a belt holster.

A variety of questions cascaded through my mind, starting with what was in the trunk and ending with whether Milton had probable cause to open it if I refused.

Another drop of what I now assumed to be bodily fluid of some sort hit the asphalt.

“Write me the ticket for the plate, Officer Milton,” I said. “But I am not opening the trunk.”

“Sir, then I am placing you under arrest,” Milton said. “Put your hands on the trunk.”

“Arrest? For what? I’m not—”

Milton moved in on me, grabbing me and spinning me toward my car. He threw all of his weight into me and doubled me over the trunk.

“Hey! You can’t—”

One at a time, my arms were roughly pulled behind my back and I was handcuffed. Milton then put his hand into the back collar of my shirt and jacket and yanked me up off the car.

“You’re under arrest,” he said.

“For what?” I said. “You can’t just—”

“For your safety and mine I’m putting you into the back of the patrol car.”

He grabbed my elbow to turn me again, and walked me to the rear passenger door of his car. He put his hand on top of my head as he pushed me into the plastic seat in the back. He then leaned across to buckle me in.

“You know you can’t open the trunk,” I said. “You have no probable cause. You don’t know if that’s blood and you don’t know if it’s coming from the interior of the car. I could’ve driven through whatever it is.”

Milton pulled back out of the car and looked down at me.

“Exigent circumstances,” he said. “There might be someone in there who needs help.”

He slammed the door. I watched him go back to my Lincoln and study the trunk lid for some sort of release mechanism. Finding none, he went to the open driver’s door and reached in to remove the keys.

He used the key fob to pop the trunk, standing off to the side should someone come out of the trunk shooting. The lid went up and an interior light went on. Milton supplemented it with his own flashlight. He moved from left to right, stepping sideways and keeping his eyes and the beam on the contents of the trunk. From my angle in the back of the patrol car, I could not see into the trunk but could tell by the way Milton was maneuvering and bending down for a closer look that there was something there.

Milton tilted his head to talk into the radio mic on his shoulder and then made a call. Probably for backup. Probably for a homicide unit. I didn’t have to see into the trunk to know that Milton had found a body.

 

Chapter 2

Sunday, December 1

Edgar Quesada sat next to me at a dayroom table as I read the last pages of the transcript from his trial. He had asked me to review his case files as a favor, hoping there was something I could see or do to help his situation. We were in the high-power module in the Twin Towers Correctional Facility in downtown Los Angeles. This was where they housed inmates on keep-away status as they waited for trial or, as in Quesada’s case, sentencing to state prison. It was the first Sunday evening in December and the jail was cold. Quesada wore white long johns under his blue jumpsuit, the sleeves all the way down to his wrists.

Quesada was in familiar surroundings. He had been down this path before and had the tattoos to prove it. He was a third-generation White Fence gang member from Boyle Heights with lots of inked allegiance to the gang and the Mexican Mafia, which was the largest and most powerful gang in California’s jail and prison systems.

According to the documents I had been reading, Quesada had been the driver of a car that carried two other members of White Fence as they fired automatic weapons through the plate-glass windows of a bodega on East First Street, where the owner had fallen two weeks behind on the gang tax that White Fence had been extorting from him for almost twenty-five years. The shooters had aimed high, the attack intended to be a warning. But a ricochet went low and hit the bodega owner’s granddaughter on the top of the head as she crouched behind the counter. Her name was Marisol Serrano. She died instantly, according to testimony I read from the deputy coroner.

No witnesses to the crime identified the shooters. That would have been a fatal exercise in bravery. But a traffic cam caught the license plate on the getaway car. It was traced to a car stolen from the long-term parking garage at nearby Union Station. And cameras there caught a glimpse of the thief: Edgar Quesada. His trial lasted only four days and he was convicted of conspiracy to commit murder. His sentencing was in a week and he was looking at a minimum of fifteen years in prison with the likelihood of many more beyond that. All because he had been behind the wheel on a drive-by warning-turned-murder.

“So?” Quesada said as I flipped the last page over.

“Well, Edgar,” I said. “I think you’re kind of fucked.”

“Man, don’t tell me that. There’s nothing? Nothing at all?”

“There’s always things you can do. But they’re long shots, Edgar. I’d say you have more than enough here for an IAC motion but—”

“What’s that?”

“Ineffective assistance of counsel. Your lawyer sat on his hands the whole trial. He let objection after objection pass. He just let the prosecutor— Well, here, you see this page?”

I moved back through the transcript to a page where I had folded a corner over.

“Here the judge even says, ‘Are you going to object, Mr. Seguin, or do I have to keep doing it for you?’ That is not good trial work, Edgar, and you might have a shot at proving that, but here is the thing: at best you win the motion and get a do over, but that doesn’t change the evidence. It’s still the same evidence and with the next jury you’ll go down again, even if you have a new lawyer who knows how to keep the prosecutor inside the lines.”

Quesada shook his head. He was not my client, so I didn’t know all the details of his life but he was about thirty-five and looking at a lot of hard time.

“How many convictions do you have?” I asked.

“Two,” he said.

“Felonies?”

He nodded and I didn’t have to say anything else. My original assessment stood. He was fucked. He was probably going away forever. Unless…

“You know why they got you here in high-power instead of the gang module, right?” I said. “Any day now they’re going to pull you out of here, put you in a room, and ask you the big question. Who was in the car with you that day?”

I gestured to the thick transcript.

“There’s nothing here that will help you,” I said. “The only thing you can do is deal the time down by giving up names.”

I said the last part in a whisper. But Quesada didn’t respond as quietly.

“That’s bullshit!” he yelled.

I checked the mirrored window of the control room overhead even though I knew I could see nothing behind it. I then looked at Quesada and saw the veins in his neck start to pulse—even beneath the inked necklace of cemetery stones that circled it.

“Cool down, Edgar,” I said. “You asked me to look at your file and that’s all I’m doing. I’m not your lawyer. You should really talk to him about—”

“I can’t go to him,” Quesada said. “Haller, you don’t know shit!”

I stared at him and finally understood. His lawyer was controlled by the very people he would need to inform on: White Fence. Going to him would almost assuredly result in a Mexican Mafia–engineered snitch shanking, whether he was in the high-power module or not. It was said that the eMe, as it was more informally known, could get to anybody anywhere in a California lockdown.

I was literally saved by the bell. The five-minute warning horn before bed check sounded. Quesada reached across the table and roughly grabbed up his documents. He was through with me. He got up while still smoothing all the loose pages into a neat stack. Without a Thank you or a Fuck you, he headed off to his cell.

And I headed to mine.

 

Chapter 3

At 8 p.m. the steel door of my cell automatically slid closed with a metallic bang that jolted my entire being. Every night it went through me like a train. I had been in lockup for five weeks now and it was something I couldn’t and didn’t ever want to get used to. I sat down on the three-inch-thin mattress and closed my eyes. I knew the overhead light would stay on another hour and I needed to use that time, but this was my ritual. To try to blank out all the harsh sounds and fears. To remind myself of who I still was. A father, a lawyer—but not a murderer.

“You got Q all hot and bothered out there.”

I opened my eyes. It was Bishop in the next cell. There was a grated air vent high up on the wall that separated our cells.

“Didn’t mean to,” I said. “I guess next time somebody needs a jailhouse lawyer in here I’ll just pass.”

“Good plan,” Bishop said.

“And where were you, by the way? It was about to become kill the messenger time with him. I looked around, no Bishop.”

“Don’t worry, homes, I had you covered. I was watching from up on the rail. I had your back.”

I was paying Bishop four hundred a week for protection, the payment delivered in cash to his girlfriend and mother of his son in Inglewood. His protection extended throughout the quarter of the high-power octagon where we were housed: two tiers, twenty-four single cells, with twenty-two other inmates presenting varying levels of known and unknown threat to me.

On my first night, Bishop had offered to protect me or hurt me. I didn’t negotiate. He usually stuck close when I was in the dayroom but I had not seen him on the second-tier walkway rail when I gave Quesada the bad news about his case. I knew very little about Bishop, because you didn’t ask questions in jail. His dark black skin hid tattoos to the point of making me wonder why he even got them. But I had been able to make out the words Crip Life inked across the knuckles of both his hands.

I reached under the bed for the cardboard file box that held my own case docs. I checked the rubber bands first. I had wrapped each of the four stacks of documents with two bands each, horizontal and vertical, with the bands crossing at distinct spots on the top sheet. This told me if Bishop or anyone else had snuck in and gone through my stuff. I had a client once who almost went down on a first-degree murder because a jailhouse snitch had gotten to the files in his cell and read enough discovery material to concoct a convincing but phony confession he claimed my client had made to him. Lesson learned. I set rubberband traps and would know if someone had looked through my paperwork.

I was now facing a first-degree murder charge myself and was going pro se—defending myself. I know what Lincoln said and probably many wise men before him and since. Maybe I did have a fool for a client, but I couldn’t see putting my future in any hands other than my own. So, in the matter of The State of California versus J. Michael Haller, the defense’s war room was cell 13, level K-10 at Twin Towers Correctional Facility.

I pulled my motions packet out of the box and snapped off the rubber bands after confirming that the documents had not been tampered with. A motions hearing was scheduled for the following morning and I wanted to prep. I had three requests before the court, beginning with a motion to lower bail. It had been set at my arraignment at $5 million, with the prosecution successfully arguing that I was not only a flight risk but a threat to witnesses in the case because I knew the inner workings of the local justice system like the back of my hand. It didn’t help that the judge handling the arraignment was the Honorable Richard Rollins Hagan, whose rulings in prior cases I had twice gotten overturned on appeal. He got some payback on me, agreeing with the prosecution’s request to more than double down on the schedule that recommended a $2 million bail for first-degree murder.

At the time, the difference between $2 million and $5 million didn’t matter. I had to decide if I wanted to put everything I had into my freedom or into my defense. I decided on the latter and took up residence in Twin Towers, qualifying for keep away status as an officer of the court who had potential enemies in all of the gen pop dorms.

But tomorrow I would stand before a different judge—one I believed I had never crossed—and ask for a reduction in bail. I had two other motions as well and now reviewed my notes so I could stand and argue before the judge instead of read.

More important than the bail motion was the discovery motion that accused the prosecution of withholding information and evidence I was entitled to, and the challenge to the probable cause of the police stop that led to my arrest.

I had to assume that Judge Violet Warfield, who had drawn the case on rotation, would put a time cap on arguments on all the motions. I would need to be ready, succinct, and on point.

“Hey, Bishop?” I said. “You still awake?”

“I’m awake,” Bishop said. “What’s up?”

“I want to practice on you.”

“Practice what?”

“My arguments, Bishop.”

“That ain’t part of our deal, man.”

“I know but the lights are about to go out and I’m not ready. I want you to listen and tell me what you think.”

At that moment the lights on the tier went out.

“Okay,” Bishop said. “Let’s hear it. But you pay extra for this.”

 

Chapter 4

Monday, December 2

In the morning, I was on the first bus to the courthouse, having dined on a baloney sandwich and a bruised red apple for breakfast. It was the same breakfast every morning and it was served again at lunch for good measure. In my five weeks here we caught a break from it on Thanksgiving only, when the baloney was replaced with a slice of pressed turkey and served at all three meals. I was long past any revulsion with the food at Twin Towers. It was the routine and now I put it away quickly and easily every breakfast and every lunch. Still, I estimated that I had already lost between ten and twenty pounds during my incarceration and I looked at it as getting down to fighting weight for what would surely be the bout of my life.

On the bus, I was with thirty-nine other inmates, most of whom were heading to morning arraignment court. As a lawyer, I had seen the wide-eyed look of fear in clients when I met them for initial consultation at first appearances. But that was always in court and always with me calming and preparing them for what lay ahead. On the buses, I was surrounded by it. Men facing their first experience of incarceration. Men who had been in lockup many times before. Rookie or recidivist, there was a palpable sense of desperation coming from all of them.

I found the bus rides to and from court to be my own moments of biggest fear. It was random selection when you were loaded on. I had no Bishop, no bodyguard. Should anything happen to me, the deputies were behind an iron grate at the front: the driver and so-called safety deputy. Their role would be simply to sort out the dead and dying when whatever happened was over. They weren’t there to protect and serve, just to move people along in the underbelly of the justice system.

This time it was one of the modern buses with compartmentalized seating, the sight of which filled me with even more dread. The newer fleet was designed after there had been full-scale riots on buses that had raged out of control. With the Sheriff’s Department responsible for the safety of inmates, the riots resulted in scores of lawsuits against the agency for failure to protect those who had been injured and killed. I had lodged a couple of those lawsuits myself and so was aware of the weaknesses of the old and new designs.

The new buses were sectioned off by steel fencing into seating compartments of eight inmates each. This way, if a fight broke out, it was contained to a maximum of eight combatants. The buses had five such compartments and were loaded back to front, filling the seats in the rear section first and so on. The prisoners were cuffed together four to a chain, with one group on either side of the aisle in each compartment.

This design also was the blueprint for a significant problem. Should the bus be in transit and a fight break out in the rear compartment, the unarmed safety deputy must unlock and move through five doors and four compartments—four tight spaces filled with inmates accused in some cases of violent crimes—to break up a fight in the fifth. The idea was preposterous, and to my thinking, the department’s solution had actually doubled down on the problem. Fights in the rear compartments were allowed to play out until the bus got to its destination. Those who could walk off did and those who couldn’t were tended to.

The bus pulled into the cavernous garage beneath the Clara Shortridge Foltz Criminal Justice Center and we were off-loaded and escorted into the building’s vertical maze of holding cells that served its twenty-four different courtrooms.

As a pro se, I was entitled to some legal niceties not afforded most of the men and women who came off the buses. I was led to a private holding cell where I could confer with my investigator and stand-in attorney—the lawyer assigned as my backup to handle the printing, filing, and in some cases fine-tuning of motions and other documents produced as part of the case. My investigator was Dennis “Cisco” Wojciechowski and the stand-in was my law partner, Jennifer Aronson.

Everything moves slowly in incarceration. My 4 a.m. wake-up at Twin Towers resulted in me getting to my private conference room at 8:40 a.m., a total travel distance of four blocks. I had brought one rubber-banded stack of documents with me—the motions—and was spreading them on the metal table when my team was shown in by a detention deputy at nine sharp.

Cisco and Jennifer were required to sit across the table from me. No handshakes or hugs. The meeting fell under attorney-client privilege and was private. But there was a camera in one corner of the ceiling. We would be watched, but the camera carried no audio back to the deputy who monitored it—or so it was claimed. I didn’t fully believe this, and during prior team meetings I had occasionally made a remark or issued an order designed to send the prosecution off on a wild-goose chase if they happened to be illegally listening in. I used the code word Baja in each statement to alert my team to the ruse.

I was in dark blue scrubs with LAC DETENTION stenciled across the front and back of my shirt. Like Edgar Quesada the evening before, I wore long johns underneath. I had learned quickly during my stay with the county that the early-morning bus rides and courthouse holding cells were unheated, and I dressed accordingly.

Jennifer was dressed for court in a charcoal-gray suit and cream-colored blouse. Cisco, as was his routine, was dressed for a sunset ride down the Pacific Coast Highway on his classic Harley Panhead, Cody Jinks blasting on his helmet stereo: black jeans, boots, and T-shirt. It appeared that his skin was impervious to the cold, damp air of the conference cell. That he was originally from Wisconsin might have had something to do with that.

“How’s my team this fine morning?” I said cheerily.

Although I was the one incarcerated and wearing the jailhouse scrubs, I knew it was important to keep my people engaged and not worried about my predicament. Act like a winner and you’ll become a winner—as David “Legal” Siegel, my father’s partner and the man who mentored me in the law, used to say.

“All good, boss,” Cisco said.

“How are you doing?” Jennifer asked.

“Better to be in the courthouse than the jail,” I said. “Which suit did Lorna pick out?”

Lorna Taylor was my case manager as well as my sartorial consultant. This second duty extended from when she was my wife—my second wife, in a union that lasted only a year and preceded her marriage to Cisco. Though I would not be appearing this day before a jury, I had previously secured Judge Warfield’s approval of a motion allowing me to dress in my professional clothes during all appearances in open court. My case had drawn considerable attention from the media and I didn’t want a photo of me in convict garb going viral. The world outside the courthouse was a jury pool from which twelve people would be drawn to judge me. I didn’t want them, whoever they were, to have already seen me in jailhouse blues. My carefully curated selection of European suits also added to my confidence when I stood before the court to argue my case.

“The blue Hugo Boss with pink shirt and gray tie,” Jennifer said. “The courtroom deputy has it.”

“Perfect,” I said.

Cisco rolled his eyes at my vanity. I ignored it.

“What about the time?” I asked. “You talk to the clerk?”

“Yes, the judge slotted an hour,” Jennifer said. “Will that be enough?”

“Probably not, with argument from Dana. I might have to drop something if Warfield sticks to the schedule.”

Dana was Dana Berg, the Major Crimes Unit star prosecutor assigned to convicting me and sending me off to prison for the rest of my life. Among members of the downtown defense bar, she was known as Death Row Dana because of her propensity to seek maximum penalties, or, alternately, as Iceberg because of her demeanor when it came to negotiating pleas. The fact was that her resolve couldn’t be melted and she was most often assigned cases where trial was inevitable.

And that was the situation with me. The day after my arrest, I had put out a media statement through Jennifer that forcefully denied the allegations against me and promised vindication at trial. It was most likely that statement that got the case assigned to Dana Berg.

“Then what do we drop?” Jennifer asked.

“Let’s put bail on the back burner,” I said.

“Wait, no,” Cisco said.

“What? I wanted to go with that right out of the gate,” Jennifer said. “We need to get you out of there and into unrestricted strategy sessions in an office, not a cell.”

Jennifer raised her hands to take in the space where we were sitting. I knew that they would both protest my decision on bail. But I intended to make better use of today’s time in front of the judge.

“Look, it’s not like I’m having a great time at Twin Towers,” I said. “It’s not the Ritz. But there are things that are more important to accomplish today. I want to get a full hearing on the probable-cause challenge. That’s number one. And then I want to argue the discovery issues. You ready on that, Bullocks?”

It had been a long time since I had called Jennifer by her baby-lawyer nickname. I had hired her right out of Southwestern Law School, which was housed in a former Bullock’s department store. I had wanted somebody with a working-class law degree and an underdog’s drive and fierceness.