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Keywords

trialmotionfelonyjury trial

defendantappealtrialmotionfelony

Related Cases

People v. Castro, 38 Cal.3d 301, 696 P.2d 111, 211 Cal.Rptr. 719

Facts

Maria Castro was convicted of receiving stolen property after a jury trial. Prior to the trial, the court denied her motion to bar impeachment with unspecified prior felony convictions should she choose to testify. The court based its ruling on the California Constitution's article I, section 28, which was enacted as part of the Victims' Bill of Rights. Castro contended that the court erred in allowing her prior convictions for possession of heroin to be used for impeachment, arguing that these convictions did not involve moral turpitude.

A jury convicted defendant Maria Castro of receiving stolen property (Pen.Code, § 496). Before trial, the court denied a motion to bar impeachment with then unspecified priors, should defendant choose to testify.

Issue

The main legal issues were whether the court erred in ruling that Castro could be impeached with her prior convictions of possession of heroin and possession of heroin for sale, and whether any such error was prejudicial.

The issues on appeal are (1) whether the court erred in ruling that defendant could be impeached with what proved to be prior convictions of possession of heroin and possession of heroin for sale, and (2) whether the error, if any, was prejudicial.

Rule

The court applied the principle that prior felony convictions may be used for impeachment purposes only if they involve moral turpitude, and that the trial court retains discretion under Evidence Code section 352 to exclude evidence that is marginally relevant but prejudicial.

The intention of the drafters of the initiative providing that any prior felony conviction shall subsequently be used without limitation for purposes of impeachment in any criminal proceeding was to restore trial court discretion as visualized by the Evidence Code and to reject rigid, black-letter rules of exclusion engrafted onto the Code by line of decisions.

Analysis

The court analyzed the language of the California Constitution's article I, section 28, and determined that while subdivision (f) mandates the use of prior felony convictions for impeachment, it does not eliminate the trial court's discretion to exclude evidence under section 352. The court concluded that simple possession of heroin does not involve moral turpitude, while possession for sale does, thus the trial court erred in allowing impeachment with the conviction for simple possession.

The legislative and judicial history of sections 352 and 788, the circumstances under which article I, section 28 was enacted, the language of the enactment—concededly ambiguous—as well as certain policy considerations convince us that section 28 was not intended to abrogate the traditional and inherent power of the trial court to control the admission of evidence by the exercise of discretion to exclude marginally relevant but prejudicial matter.

Conclusion

The court affirmed the conviction, concluding that the error in admitting the prior conviction for simple possession of heroin was not prejudicial to the outcome of the trial.

Error in permitting impeachment with prior conviction for simple possession of heroin, an offense not necessarily involving moral turpitude, was not prejudicial.

Who won?

The People (prosecution) prevailed in the case because the court upheld the conviction despite the error regarding the impeachment evidence.

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