People v. Brady

34 Cal. App. 4th 65, 40 Cal. Rptr. 2d 207, 95 Cal. Daily Op. Serv. 2886, 95 Daily Journal DAR 4912, 1995 Cal. App. LEXIS 362
CourtCalifornia Court of Appeal
DecidedApril 18, 1995
DocketD021274
StatusPublished
Cited by10 cases

This text of 34 Cal. App. 4th 65 (People v. Brady) 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. Brady, 34 Cal. App. 4th 65, 40 Cal. Rptr. 2d 207, 95 Cal. Daily Op. Serv. 2886, 95 Daily Journal DAR 4912, 1995 Cal. App. LEXIS 362 (Cal. Ct. App. 1995).

Opinion

Opinion

HUFFMAN, J.

In this case we deal with the narrow issue of whether the “total term of imprisonment imposed” upon John Thomas Brady also includes the one year imposed for the prior prison term he admitted he had served for purposes of calculating the amount of credits he can now be awarded while sentenced to prison pursuant to the newly enacted “three strikes” law. (See Pen. Code, 1 § 667, subds. (b)-(i), specifically (c)(5).) 2 We conclude that it does.

*67 Background

On June 1, 1994, Brady pleaded guilty to the unlawful taking and driving of Jennifer Koslow’s vehicle (Veh. Code, § 10851, subd. (a)) on April 11, 1994. 3 He also admitted he had suffered an earlier serious felony conviction (armed robbery, §§ 211/12022.5) that qualified as a “strike” under the “three strikes” statute (§ 667, subds. (d), (e)(1)) and had served a prior prison term. (§ 667.5, subd. (b).) Brady stipulated to a total five-year term consisting of a four-year term for the current charge (based on doubling the middle term of two years under § 667, subd. (e)(1)) 4 and an additional one year for the prison prior. On the prosecutor’s motion the trial court dismissed a charge of receiving stolen property (§ 496, subd. (a)) and another prison prior. (§ 667.5, subd. (b).)

Brady waived the right to a probation report and was immediately sentenced pursuant to his agreement. 5 Afterwards, Brady personally addressed the court, stating: “I am just curious. When you sentenced me to the mid term of two years and doubled it to four, I’ve got to do 80 percent of that. Is that right?” When the court answered affirmatively, Brady questioned whether the “year for the prison prior” falls under the same 80 percent rule.

The prosecutor and the court were of the opinion Brady would serve “80 percent of any of the total term.” In response to Brady’s counsel’s belief the *68 law was unclear in that regard, because the one year could not be doubled (defense counsel thus thought the “50 percent would apply”), the court stated: “Well, the way the law is written and there hasn’t been any kind of interpretation of it, that it can be interpreted both ways. I think to be on the safe side—I think that the best for you is to keep on top of it and after the four years has been served if there is any question still remaining as to how your year should be completed [as] to your good time credits[,] that should be brought up to the department of corrections.”

On June 3, 1994, Brady filed a notice of appeal that stated it was “based on the sentence or other matters occurring after the plea.”

Discussion

Brady appeals, 6 contending the trial court erred in ordering him to serve 80 percent of his prior prison term in addition to the term it imposed under the “three strikes” statute. The gist of his arguments is that a correct interpretation of the words “the total term of imprisonment imposed” in section 667, subdivision (c)(5) does not include application of the “80 percent” rule, which changes the credits certain recidivist prisoners may earn towards reducing their terms of imprisonment, to an enhancement not mentioned in section 667, i.e., a nonviolent or nonserious prior conviction enhancement. He specifically argues proper statutory construction reveals the Legislature did not intend by its enactment of section 667, subdivision (c)(5) to “entirely dismantle section 2931,” but rather to leave prisoners, like him, the option of reducing that portion of their terms for nonserious and nonviolent felony convictions via “good behavior and willingness to work.” 7 He thus asserts the application of section 667, subdivision (c)(5) to his

*69 People v. Brady

34 Cal.App.4th 65; 40 Cal.Rptr.2d 207 [Apr. 1995]

one-year enhancement violates the prohibition against ex post facto laws by decreasing the amount of credits he may earn and denies him his constitutional right to due process because the new “three strikes” law failed to give him notice “computation of good time credits would not apply to an enhancement for a prison prior. . . .”

We conclude the trial court did not err in stating the “80 percent” rule of section 667, subdivision (c)(5) would apply to Brady’s one-year prison prior enhancement since that enhancement was included within his “total term,” and no ex post facto or due process violation is shown by such application.

I

“Total Term of Imprisonment Imposed'

Brady’s assertions the specific language “the total term of imprisonment imposed” contained in section 667, subdivision (c)(5), does not include his one-year enhancement for his prison prior (or any other nonviolent or nonserious prior felony conviction enhancement) and is somehow ambiguous simply ignore the plain language of that section, the intent of the Legislature in enacting that section, and the entire sentencing scheme of which that section is a part.

As noted earlier, section 667, subdivision (c)(5) provides: “Notwithstanding any other law, if a defendant has been convicted of a felony and it has been pled and proved that the defendant has one or more prior felony convictions as defined in subdivision (d), the court shall adhere to each of the following: [<JD . . . [U (5) The total amount of credits awarded pursuant to Article 2.5 (commencing with Section 2930) of Chapter 7 of Title 1 of Part 3 shall not exceed one-fifth of the total term of imprisonment imposed and shall not accrue until the defendant is physically placed in the state prison.” (Italics added.)

apply to defendants not sentenced under a “strike,” subdivision (d) of 2931 provides that section does not apply to “any person whose crime was committed on or after January 1, 1983.”

We presume Brady, whose crime was committed in April of 1994, and the People, meant to refer to section 2933, which at the time of Brady’s appeal provided for “worktime credits” earned (for up to 50 percent of a prison term) through various programs (see In re Ramirez (1985) 39 Cal.3d 931, 936 [218 Cal.Rptr. 324, 705 P.2d 897]; 3 Witkin & Epstein, Cal. Criminal Law (2d ed. 1989) Punishment For Crime, § 1558, pp. 1861-1862), and which Brady would have been entitled to earn credits under but for his status under section 667, subd. (e).

Brady has not contested his qualifying repeat offender status under the “three strikes” statute nor raised any equal protection issues on this appeal. (See People v. Culpepper * (CaLApp.); People v. Caruso (1984) 161 Cal.App.3d 13, 20-21 [207 Cal.Rptr. 221]; In re Bender (1983) 149 Cal.App.3d 380, 386-390 [196 Cal.Rptr. 801].)

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Bluebook (online)
34 Cal. App. 4th 65, 40 Cal. Rptr. 2d 207, 95 Cal. Daily Op. Serv. 2886, 95 Daily Journal DAR 4912, 1995 Cal. App. LEXIS 362, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-brady-calctapp-1995.