People v. Bolanos CA5

CourtCalifornia Court of Appeal
DecidedMarch 24, 2025
DocketF082970A
StatusUnpublished

This text of People v. Bolanos CA5 (People v. Bolanos CA5) 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. Bolanos CA5, (Cal. Ct. App. 2025).

Opinion

Filed 3/24/25 P. v. Bolanos CA5 Opinion following transfer from Supreme Court

NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIFTH APPELLATE DISTRICT

THE PEOPLE, F082970 Plaintiff and Respondent, (Super. Ct. No. MCR063072) v.

CARLOS ALFONSO BOLANOS, OPINION Defendant and Appellant.

APPEAL from a judgment of the Superior Court of Madera County. Mitchell C. Rigby, Judge. Jean M. Marinovich, under appointment by the Court of Appeal, for Defendant and Appellant. Rob Bonta, Attorney General, Lance E. Winters, Chief Assistant Attorney General, Michael P. Farrell and Kimberley A. Donohue, Assistant Attorneys General, Eric L. Christoffersen, Kenneth N. Sokoler, and Ross K. Naughton, Deputy Attorneys General, for Plaintiff and Respondent. -ooOoo- Carlos Alfonso Bolanos was 22 years old when he committed various sex crimes for which he was sentenced to serve, inter alia, multiple life in prison without parole and multiple life in prison with parole terms. These sentences were based on the One Strike law (Pen. Code,1 § 667.61). On an unrelated occasion, he stole a car and was convicted for its theft. In a prior appeal, we addressed numerous contentions, primarily relating to the sentence imposed and parole eligibility. Bolanos petitioned for review in the California Supreme Court. The petition was granted and deferred pending resolution in three separate cases. After those cases were resolved, the Supreme Court transferred the matter back to this court, “with directions to vacate [our] decision and reconsider the cause in light of In re Vaquera (2024) 15 Cal.5th 706 [(Vaquera)].” We have reconsidered the cause. We will issue substantially the same opinion, except that we apply Vaquera and its principles to reach the same conclusion in part II., post. In all other respects, the prior opinion will stand. OVERVIEW In sum, Bolanos makes several claims, mostly related to sentencing. Primarily, he suggests the youthful offender parole scheme—which excludes people sentenced under the One Strike law, and people sentenced to life without parole for crimes committed as adults—violates equal protection. (See § 3051, subd. (h).) The People dispute any equal protection violation. Second, Bolanos complains the court erred in pronouncing one of the life in prison with parole terms. The People concede, but the parties diverge on the appropriate remedy. Their disagreement centers on due process and notice. Third, Bolanos contends the trial court should have stayed some of the One Strike sentences pursuant to section 654, which generally prohibits multiple punishment for a single act. The People disagree. We find against Bolanos on these three issues. We also address his remaining contentions—which we further detail below. Ultimately, we will reverse the car theft

1 All statutory references are to the Penal Code.

2. conviction for insufficient evidence, direct the court to stay certain other sentences, and remand for resentencing. The judgment, including the life without parole terms, is otherwise affirmed. BACKGROUND Charges The Madera County District Attorney charged Bolanos with numerous crimes and special allegations. The following crimes were charged: forcible rape (§ 261, subd. (a)(2); Counts 1 & 2), forcible oral copulation of a minor (§ 287, subd. (c)(2)(C); Count 3), aggravated kidnapping (§ 209, subd. (b)(1); count 4), forcible oral copulation (§ 287, subd. (c)(2)(A); Count 5), criminal threats (§ 422, subd. (a); Count 6), false imprisonment (§ 236; Count 7), vehicle theft (Veh. Code, § 10851, subd. (a); Count 8), and grand theft automobile (§ 484/487, subd. (d)(1); Count 9). The charges included the following special allegations: aggravated kidnapping in Counts 1, 2, and 3 (§ 667.61, subds. (l) & (d)(2)), aggravated kidnapping in Counts 1, 2, and 3 (§ 667.61, subds. (a) & (d)(2)), kidnapping in Counts 1, 2, and 3 (§ 667.61, subds. (a) & (e)(1)), kidnapping in Count 5 (§ 667.61, subds. (b) & (e)(1)),2 and multiple victims (§ 667.61, subds. (a) & (e)(4)). Trial Evidence There are three victims in this case. We will summarize the evidence relative to each victim in the order presented at trial. In each incident, Bolanos used his “girlfriend” or a fake Facebook3 profile to contact the victim. The fake profile was named “Maritza Martinez” and depicted a “Mexican” “teenage girl ….”4

2 The basis for this special allegation is subject to some debate and discussed further below. 3 Facebook is a “social media service provider[] ….” (Facebook, Inc. v. Superior Court (2018) 4 Cal.5th 1245, 1248.) 4 Victim one provided the Maritza Martinez description at the trial.

3. Victim One: Counts 1 through 4 (forcible rape, forcible oral copulation, kidnapping) Victim one agreed to meet Maritza Martinez for a job. At the last minute, victim one was told Bolanos would meet her instead and he indeed showed up in a van. Victim one entered, believing she would help sell fruit. Bolanos drove her down the street and then forced her to perform oral sex. He then drove her to a second location, raped her, took her back to the first location, and then raped her again. To accomplish the acts, Bolanos verbally threatened the victim with a weapon.5 Victim Two: Counts 5 through 7 (forcible oral copulation, criminal threats, false imprisonment) Victim two agreed to meet her friend at the friend’s home, a trailer.6 Her friend was in a relationship with Bolanos. When victim two arrived at the trailer, she hesitated to enter and remained outside until Bolanos approached and “told [her] go in” because her friend “was in there.” After she complied by entering, Bolanos told her her friend was not home. Victim two tried to leave but Bolanos blocked the door, held a knife to her “stomach,” threatened to “stab her,” and forced her to perform oral sex. Victim Three: Counts 8 and 9 (vehicle theft, grand theft automobile) Victim three agreed to sell her car to Maritza Martinez. At the last minute, victim three was told Bolanos would meet her instead. Bolanos showed up, test drove the car, and then victim three signed over the “pink slip ….” After signing over the “pink slip,” Bolanos handed victim three fake money concealed in an envelope. Victim three exited the car, ultimately realized the money was fake, and Bolanos drove off the with car.

5 Bolanos did not display a weapon during the threats.

6 Victim two and her friend—Bolanos’s girlfriend—communicated through Facebook. Bolanos “kicked” his girlfriend “out” after she invited victim two to visit. The girlfriend testified she invited her friend over at Bolanos’s request and complied “[b]ecause he was going to hit [her] if [she] didn’t [do] it.” She also helped him use the Maritza Martinez profile to arrange the meeting with victim three.

4. Verdict and Sentence The jury found Bolanos guilty on each charged crime. The jury found the aggravated kidnapping special allegations to Count 1 not true (§ 667.61, subds. (l) & (d)(2) and (a) & (d)(2)). It also found the kidnapping special allegation to Count 5 not true (§ 667.61, subd. (b) & (e)(1)). The remaining special allegations were found true. The court sentenced Bolanos to serve life without parole on Counts 2 and 3, 25 years to life on Counts 1 and 5, seven years to life on Count 4,7 and four years, four months on Counts 6 through 9. Only the Count 9 term was stayed. DISCUSSION This appeal presents numerous issues. We address the issues in the following order.

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Bluebook (online)
People v. Bolanos CA5, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-bolanos-ca5-calctapp-2025.