People v. Brown CA4/3

CourtCalifornia Court of Appeal
DecidedOctober 22, 2025
DocketG064132
StatusUnpublished

This text of People v. Brown CA4/3 (People v. Brown CA4/3) 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. Brown CA4/3, (Cal. Ct. App. 2025).

Opinion

Filed 10/22/25 P. v. Brown CA4/3

NOT TO BE PUBLISHED IN OFFICIAL REPORTS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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FOURTH APPELLATE DISTRICT

DIVISION THREE

THE PEOPLE,

Plaintiff and Respondent, G064132

v. (Super. Ct. No. RIF2103706)

LOUIS EDWARD BROWN, OPINION

Defendant and Appellant.

Appeal from a judgment of the Superior Court of Riverside County, James S. Hawkins, Judge. Affirmed in part and reversed in part. Law Offices of Brad Poore and Brad J. Poore, under appointment by the Court of Appeal, for Defendant and Appellant. Rob Bonta, Attorney General, Lance E. Winters, Chief Assistant Attorney General, Charles C. Ragland, Assistant Attorney General, Christopher P. Beesley and Caelle Oetting, Deputy Attorneys General, for Plaintiff and Respondent. After a jury convicted defendant Louis Edward Brown of rape of an unconscious person (Pen. Code, § 261, subd. (a)(4)) and kidnapping (id. at § 207), the trial court sentenced him to an aggregate prison term of nine years and eight months. On appeal, he contends the court erred in admitting evidence of a decades old uncharged alleged prior rape over his Evidence Code section 352 objection.1 He also argues the court committed constitutional and statutory error in imposing the upper term sentence on the rape count based on aggravating factors not tried to the jury. We find no abuse of discretion concerning the admission of evidence, but agree the court prejudicially erred in its use of aggravating factors during sentencing. Accordingly, we vacate Brown’s sentence and remand the matter for further sentencing related proceedings, but we otherwise affirm the conviction. FACTS

One evening in mid-2021, L.L. and her husband, T.L., decided to have drinks at a couple of places they occasionally frequented in the downtown area of the City of Riverside. T.L. drove that night. L.L. had two martinis at the first location and a scotch whiskey, which the bartenders potentially topped off a couple of times, at the second. Toward the end of the night, she and her husband got into an argument. She became frustrated with not winning the argument, so she left and told her husband she would meet him at the car. L.L. walked toward the locations where they normally parked their car when they came to downtown Riverside, but she could not locate it. As she walked, she started to feel the effects of the alcohol she had consumed.

1 All further statutory references are to the Evidence Code unless

indicated otherwise.

2 With her high-heeled shoes in hand, figuring T.L. had already driven off in the car, L.L. decided to walk along the route they would typically take to get home thinking he might see her. The area was very dark, so she made her way to a more frequented and well-lit street. As L.L. continued down the street, feeling dizzy and having trouble balancing, she tripped and fell. Her shin hit the curb. As she struggled to stand up and regain her footing, a gold pickup truck approached. An African American male, later identified as Brown, stopped the truck and approached L.L. After she told him “I’m fine,” he opened the right-side doors of his truck. As he “eased her down” “very gentl[y]” onto the rear passenger seat of the truck, L.L. was confused but thought Brown was trying to help her. After Brown quickly shut the truck doors, L.L. could not locate a door handle to open the rear passenger door. After other events transpired, some of the facts of which were disputed at trial, Brown stopped at a gas station. While he was inside the convenience store, L.L. got out of the truck and ran away. She eventually connected with T.L. who came to pick her up. A couple of days later, L.L. told T.L. that Brown raped her. Brown was arrested and charged with one count of rape of an unconscious person and one count of kidnapping with an intent to commit rape. Among those testifying at trial were L.L., T.L., and a police detective who spoke both to L.L. after she reported what happened and to Brown when he was arrested. At trial, L.L. testified Brown did not speak much when he picked her up. Shortly after he closed the doors to the truck, she said to him, “I appreciate what you’re trying to do, but if you could just drop me off at the next intersection and let me out so I can stand on a sidewalk. Then my

3 husband can see me, and I can get a ride home.” Brown did not respond and he drove past the next intersection. L.L., starting to panic, then asked him to “just drop [her] off at the next spot where there[] [was] a sidewalk.” He did not respond or stop, and shortly thereafter L.L. “passed out.” The next thing L.L. remembered was feeling pressure on her lower abdomen and opening her eyes to see Brown finishing having sexual intercourse with her. He seemed calm, but looked around and told her, “It’s not safe here. We have to go someplace else.” L.L. felt terrified and asked if he was “going to take [her] someplace safe.” He confirmed he was. They drove to a gas station and Brown asked L.L. if she wanted anything; she declined. As soon as he was inside the convenience store, she climbed into the front seat and exited the truck through the driver’s side door which was unlocked. As she ran away, she encountered a few people who she told some variation of the following: “That man gave me a ride, and he wouldn’t let me out of the truck. And I think he was going to try to hurt me”; “Please, please don’t get yourself involved. I just need to get away from here.” When she reached the well-lit sidewalk adjacent to a nearby fast food restaurant, she was approached by a woman who offered to call T.L. for her. L.L. declined the offer, but looked in her own clutch purse and saw her phone which she had thought all along she did not have. After unsuccessfully attempting to get a rideshare home, L.L. eventually spoke to T.L. on the phone and he came to pick her up. Because she felt “ashamed” and “stupid,” she did not tell him at that time what had happened. A few days later, after reporting the incident to law enforcement, L.L. told T.L. T.L. testified that after he and L.L. got into an argument on the night in question, L.L. left and he intended to pay the bill and catch up with

4 her. It was shortly before 2 a.m. and he tried, but he could not find her. After numerous phone calls and text messages to L.L. with no response, she finally called him around 3 a.m. She sounded afraid, panicked, and stressed, and she could not articulate her location. By describing things around her, T.L. figured out where she was and went to pick her up. For the next couple of days, L.L. went along with T.L. wherever he went, which T.L. said was unusual. In conjunction with cross-examination of the police detective who interviewed Brown upon his arrest, the jury watched the videotaped interview with Brown. Brown explained he had a job but was homeless and slept in his truck. He said he would often drive around when he was aroused, “look for a lady,” tell them he wanted to have sexual intercourse, and then drop them off after. But he denied ever forcing anyone against their will. As for the night in question, Brown admitted during the interview that he picked up L.L. as she was walking down the street and had sexual intercourse with her in his truck. However, his details of exactly what took place were different than what L.L. described. He repeatedly denied doing anything against L.L’s will and denied using any force. Brown recalled stopping his truck when he saw L.L. walking on the side of the road and asking if she needed help.

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People v. Brown CA4/3, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-brown-ca43-calctapp-2025.