People v. Arvizu CA4/1

CourtCalifornia Court of Appeal
DecidedOctober 15, 2015
DocketD067503
StatusUnpublished

This text of People v. Arvizu CA4/1 (People v. Arvizu CA4/1) 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
People v. Arvizu CA4/1, (Cal. Ct. App. 2015).

Opinion

Filed 10/15/15 P. v. Arvizu CA4/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

COURT OF APPEAL, FOURTH APPELLATE DISTRICT

DIVISION ONE

STATE OF CALIFORNIA

THE PEOPLE, D067503

Plaintiff and Respondent,

v. (Super. Ct. No. JCF28330)

DONALD EDWARD ARVIZU,

Defendant and Appellant.

APPEAL from an order of the Superior Court of Imperial County, Poli Flores, Jr.,

Judge. Reversed and remanded with directions to resentence.

Donna L. Harris, under appointment by the Court of Appeal, for Defendant and

Appellant.

Kamala D. Harris, Attorney General, Julie L. Garland, Assistant Attorney General,

Eric A. Swenson and Daniel Hilton, Deputy Attorneys General, for Plaintiff and

Respondent. In 2012, Donald Edward Arvizu pleaded guilty to one felony count of receiving

stolen property. (Pen. Code,1 § 496, subd. (a).) The superior court sentenced Arvizu to

365 days in county jail and three years formal probation.

In January 2015, Arvizu unsuccessfully petitioned to have his felony conviction

converted to a misdemeanor under Proposition 47. In his petition, Arvizu argued his

violation of section 496 should be characterized as a misdemeanor because the value of

the stolen property was less than $950. The trial court, however, found Arvizu was not

entitled to relief because the value of the property was $2,000.

On appeal Arvizu argues he is eligible for resentencing because the record of

conviction does not show the value of the stolen property exceeded $950 and the trial

court abused its discretion by admitting evidence that showed otherwise. Because there

was not a sufficient evidentiary foundation to support the trial court's finding that the

property was worth $2,000, we reverse the court's order denying Arvizu's petition and

remand with directions to resentence.

FACTUAL AND PROCEDURAL BACKGROUND

In February 2012, Calexico police officer Steven Garcia saw Arvizu exit a church

parking lot with a purse in his hand. When Garcia approached Arvizu, Arvizu attempted

to hide the purse under a parked car. Garcia arrested Arvizu and retrieved the purse,

which contained pieces of broken glass. Another officer, Officer Navarro, located a car

1 All further statutory references are to the Penal Code unless otherwise specified. 2 in the parking lot with a broken window. The officers could not locate the owner of the

car and left the scene.

When the driver of the car, Adrianna Lopez, returned she noticed the car window

was broken and the purse she left inside was missing. Lopez contacted police and

reported that her car had been broken into and her purse stolen. Later, Officer Garcia

contacted Lopez, who told him her purse contained $160, several credit cards and her

passport. Lopez also told Garcia the purse and its contents were worth $2,000.

Arvizu was originally charged by felony complaint with burglary of a motor

vehicle (§ 459, count 1) and receiving stolen property (§ 496, subd. (a); count 2). He

waived his right to a jury trial and entered a guilty plea to receiving stolen property

(§ 496, subd. (a)). The change of plea form indicated the parties stipulated to the factual

basis for the plea, and at the time Arvizu entered his plea, the trial court stated: "There is

a factual legal basis for the plea." The court, however, did not provide a description of

the property stolen or assign a value.

After Arvizu entered the plea, a probation officer contacted Lopez to determine

the value of the purse in advance of the sentencing hearing. Lopez told the probation

officer she had to dispose of the purse because of damage caused by the broken glass.

Lopez also told the officer the purse was worth $50 and that was the total amount she was

requesting as restitution.

At the sentencing hearing, the court sentenced Arvizu to 365 days in county jail

and three years probation. The court ordered Arvizu to pay $50 in restitution to Lopez, in

addition to $200 for the broken car window.

3 In January 2015, Arvizu filed a petition for resentencing under Proposition 47 to

convert his conviction to a misdemeanor. Arvizu argued he was eligible for resentencing

because the value of the property he stole was less than $950. At the resentencing

hearing, Arvizu argued that the specified detailed losses as outlined by Lopez to the

probation officer were $410. The trial court, however, relied on the $2,000 figure

contained in the probation report and denied Arvizu's petition.

DISCUSSION

Arvizu asserts the trial court abused its discretion by relying on inadmissible

hearsay contained in a probation officer's report to deny Arvizu's petition. The Attorney

General contends Arvizu's hearsay objection is forfeited because he failed to raise the

issue in the trial court. Further, even if the probation report constitutes hearsay, the trial

court did not err by considering the report because evidentiary boundaries are less

rigorous at sentencing hearings.

I

Proposition 47 amended various provisions of the Penal and Health and Safety

Codes to reduce specified drug and theft offenses, including section 496, to

misdemeanors unless the crime is committed by an ineligible defendant. (People v.

Lynall (2015) 233 Cal.App.4th 1102, 1108.) As amended by Proposition 47, section 496

mandates that the offense of receiving stolen property be characterized as a misdemeanor

where the value of the property does not exceed $950. (See §§ 496, 1170.18, subd. (a).)

Proposition 47 also added section 1170.18, which allows "[a] person currently

serving a sentence for a conviction, whether by trial or plea, of a felony or felonies who

4 would have been guilty of a misdemeanor under [Proposition 47 had it] been in effect at

the time of the offense" to "petition for a recall of sentence" and request resentencing.

(§ 1170.18, subd. (a).)

We review the trial court's ruling to admit hearsay evidence under the deferential

abuse of discretion standard (People v. Alvarez (1996) 14 Cal.4th 155, 201), but review

the trial court's underlying factual determination for substantial evidence. (People v.

Kraft (2000) 23 Cal.4th 978, 1036.)

II

The Attorney General contends Arvizu forfeited his right to complain about the

trial court's consideration of the probation report because Arvizu failed to object at the

time the evidence in question was presented.

To encourage prompt detection and correction of error, and to reduce the number

of unnecessary appellate claims, reviewing courts require parties to raise certain issues at

the time of sentencing. In such cases, lack of a timely and meaningful objection forfeits

or waives the claim. (People v. Welch (1993) 5 Cal.4th 228, 234-235.) The purpose of

the waiver rule is to ensure the error is brought to the attention of the trial court, both

parties are heard on the issue, and the trial court has an opportunity to correct the error

before issuing a final judgment. (People v. Scott (1994) 9 Cal.4th 331, 353.)

In this case, at the resentencing hearing, defense counsel argued that the value of

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Chapman v. California
386 U.S. 18 (Supreme Court, 1967)
People v. Alvarez
926 P.2d 365 (California Supreme Court, 1996)
People v. Peterson
511 P.2d 1187 (California Supreme Court, 1973)
People v. Price
821 P.2d 610 (California Supreme Court, 1991)
People v. Arbuckle
587 P.2d 220 (California Supreme Court, 1978)
People v. Watson
299 P.2d 243 (California Supreme Court, 1956)
People v. Eckley
20 Cal. Rptr. 3d 555 (California Court of Appeal, 2004)
People v. Lamb
90 Cal. Rptr. 2d 565 (California Court of Appeal, 1999)
People v. Hove
91 Cal. Rptr. 2d 128 (California Court of Appeal, 1999)
People v. Kraft
5 P.3d 68 (California Supreme Court, 2000)
People v. Rodrigues
885 P.2d 1 (California Supreme Court, 1994)
People v. Lynall
233 Cal. App. 4th 1102 (California Court of Appeal, 2015)
People v. Welch
5 Cal. 4th 228 (California Supreme Court, 1993)
People v. Scott
885 P.2d 1040 (California Supreme Court, 1994)
People v. Roberts
195 Cal. App. 4th 1106 (California Court of Appeal, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
People v. Arvizu CA4/1, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-arvizu-ca41-calctapp-2015.