Nevarez v. Superior Court

CourtCalifornia Court of Appeal
DecidedOctober 27, 2025
DocketD085897
StatusPublished

This text of Nevarez v. Superior Court (Nevarez v. Superior Court) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Nevarez v. Superior Court, (Cal. Ct. App. 2025).

Opinion

Filed 10/27/25

CERTIFIED FOR PUBLICATION

COURT OF APPEAL, FOURTH APPELLATE DISTRICT

DIVISION ONE

STATE OF CALIFORNIA

JOSE HARO NEVAREZ, D085897

Petitioner, (San Diego County Super. Ct. No. SCD301522) v.

THE SUPERIOR COURT OF SAN DIEGO COUNTY,

Respondent;

THE PEOPLE,

Real Party in Interest.

ORIGINAL PROCEEDING in prohibition. Laura Parsky, Judge. Petition denied. Jo E. Super, Chief Deputy Public Defender and Ryan M. Ahern, Deputy Public Defender, for Petitioner. No appearance for Respondent. Summer Stephan, District Attorney, Dwaine Woodley, Assistant District Attorney, Linh Lam, Valerie Ryan, Emmaline Campbell and Carrie Johnson, Deputy District Attorneys, for Real Party in Interest. Jose Haro Nevarez was driving while intoxicated when he caused a collision on Interstate-15 that resulted in the death of a motorcyclist. The motorcyclist struck Nevarez’s SUV minutes after it was rendered disabled on the freeway. Thereafter, Nevarez was charged with second-degree murder

(Pen. Code, § 187, subd. (a)), 1 among other crimes. After a magistrate found probable cause to support the charges, Nevarez’s defense counsel filed a motion under section 995 to set aside the murder charge. Nevarez argued that under this court’s decision in People v. Superior Court (Chagolla) (2024) 102 Cal.App.5th 499 (Chagolla), the murder charge could not proceed because his vehicle was inoperable at the time it was struck by the victim’s motorcycle. The trial court denied the motion, finding Chagolla distinguishable. Nevarez then filed a petition for writ of prohibition asking this court to overturn the trial court’s order and we issued an order to show cause. As we shall explain, we agree with the trial court that probable cause supports the murder charge and deny Nevarez’s petition. We also accept the parties’ invitation to clarify our decision in Chagolla and hold that liability for murder under the Supreme Court’s decision in People v. Watson (1981) 30 Cal.3d 290 (Watson) does not automatically end the moment an intoxicated driver ceases driving. FACTUAL AND PROCEDURAL BACKGROUND On December 1, 2023, around 9:54 p.m., Nevarez was driving a Honda Pilot southbound on Interstate-15 (I-15). Witnesses testified at the preliminary hearing that before the collision Nevarez was driving between 90

1 Subsequent undesignated statutory references are to the Penal Code.

2 to 100 miles per hour in a 65-mile-per-hour zone. In the area of the crash, there were five general lanes of traffic and two high-occupancy vehicle (HOV) lanes. Nevarez was in the farthest left general lane (the number one lane) and crashed into the rear of a Honda Odyssey in front of him, causing the Odyssey to spin clockwise to the right and fly across all five general lanes of traffic. As the Odyssey spun, it struck a Ford box truck that was traveling in the number four lane. The impact sent the box truck and the Odyssey to the right shoulder of the freeway. After it hit the Odyssey, Nevarez’s Pilot side- swiped an Audi A7 sedan in the far left general lane. The Pilot then veered left across the two HOV lanes and came to a stop against the concrete barrier wall, blocking the number one HOV lane. At that point, the Pilot was disabled and all of its lights were off. At the same time, motorcyclist Robert Cole Sutton was traveling south in the number one HOV lane. Sutton had a motorcycle permit and was not speeding. Moments after Nevarez struck the Odyssey, as the Odyssey’s driver was on the phone with 911, Sutton struck the right rear of Nevarez’s Pilot. The force of the collision detached Sutton’s left leg from his body, and he was thrown approximately 200 feet down the road in front of the Pilot. First responders pronounced Sutton deceased at 10:39 p.m. Moments after the crash, around 9:56 p.m., California Highway Patrol (CHP) officer Justin Wooten was on patrol on southbound I-15 when he came upon the crash site. Wooten was driving in the number one HOV lane, saw the Pilot blocking the lane, and swerved to avoid hitting it. After he passed the accident, he exited the freeway and returned to the scene. Soon after Wooten passed the scene, CHP officer Garret Larson stopped near the Pilot and found Nevarez pacing near the car. Nevarez told Larson, who was joined by Wooten, “I fucked up. I’m drunk.” Nevarez also said he was “drunk and

3 tired, closed his eyes, and he hit the concrete wall.” He said after the collision with the wall he could not get out of the car, and within three or four minutes of the collision Sutton’s motorcycle struck the Pilot. Wooten testified Nevarez was exhibiting signs of alcohol intoxication. Wooten conducted a series of field sobriety tests that Nevarez failed. Nevarez also admitted he was drinking at his friend’s house before the accident and felt “buzzed.” Wooten told Nevarez he was required to provide a breath sample using a preliminary alcohol screening (PAS) device because he was on DUI probation for a prior conviction. Nevarez acknowledged he was on DUI probation, and told Wooten this was going to be a “Watson charge.” Nevarez’s PAS results, about 90 minutes after the collision, were 0.168 and 0.165 percent. Later, Nevarez provided a blood sample, which showed that over three hours after the crash his blood alcohol level was 0.155 percent. Nevarez was convicted of driving under the influence in connection with an incident that occurred on October 31, 2021. On that date, around 1:08 a.m., Larson and his partner were patrolling and saw Nevarez driving between 100 and 115 miles per hour on multiple highways. The officers pulled Nevarez over, and he appeared to be under the influence of alcohol. After conducting field sobriety tests, the officers gave Nevarez a PAS test that showed his blood alcohol level was between 0.181 and 0.187 percent. The officers arrested Nevarez, and Larson read him a Watson admonishment, stating: “[D]riving under the influence is dangerous, and while the defendant had not been convicted yet, if convicted, and then involved in a motor vehicle accident in the future where the defendant was under the influence of alcohol, and somebody lost their life as a result of that collision, they could be charged with murder, as opposed to manslaughter.”

4 Two years later, Larson encountered Nevarez at the scene of the present crash. On December 6, 2023, the People filed a felony complaint charging Nevarez with murder in violation of section 187, subdivision (a) (count 1); gross vehicular manslaughter while intoxicated in violation of section 191.5, subdivision (a) (count 2); DUI causing injury with a prior DUI conviction within ten years in violation of Vehicle Code section 23153, subdivision (a) (count 3); and driving with a blood alcohol content of 0.08 percent or higher causing injury with a prior DUI within 10 years in violation of Vehicle Code section 23153, subdivision (b) (count 4). Multiple special allegations were attached to counts 2, 3, and 4. Nevarez was arraigned and entered a plea of not guilty to all charges. The preliminary hearing took place on January 27, 2025. The magistrate made a factual finding that the fatal collision in this case occurred “within two minutes” of Nevarez’s Pilot hitting the Odyssey. At the hearing, defense counsel argued the People presented insufficient evidence to support the murder charge. Specifically, counsel argued that under Chagolla, supra, 102 Cal.App.5th 499, he could not be held to answer for a fatal collision that occurred after he ceased driving. After extensive argument about Chagolla, the magistrate acknowledged both the majority and concurring opinions and concluded this case was “factually distinguished in critical ways” from Chagolla. The magistrate bound over on all counts, and added two additional great bodily injury allegations.

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Nevarez v. Superior Court, Counsel Stack Legal Research, https://law.counselstack.com/opinion/nevarez-v-superior-court-calctapp-2025.