People v. Chao CA3

CourtCalifornia Court of Appeal
DecidedDecember 12, 2022
DocketC087388
StatusUnpublished

This text of People v. Chao CA3 (People v. Chao CA3) 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. Chao CA3, (Cal. Ct. App. 2022).

Opinion

Filed 12/12/22 P. v. Chao CA3 NOT TO BE PUBLISHED California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published,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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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 THIRD APPELLATE DISTRICT (Sacramento) ----

THE PEOPLE, C087388

Plaintiff and Respondent, (Super. Ct. No. 15F06554)

v.

ALLEN FINH CHAO et al.,

Defendants and Appellants.

A jury found defendants Allen Finh Chao and Gerald Oryan Fernandez guilty of attempted murder (count 1) and second-degree robbery (count 2). The jury also found true that both defendants personally and intentionally discharged a firearm causing great bodily injury in the commission of both offenses. (Pen. Code, § 12022.53, subd. (d).)1 On appeal, Chao argues: (1) the trial court’s admission of Fernandez’s hearsay

1 Undesignated statutory references are to the Penal Code.

1 statements as declarations against interest at their joint trial violated his right to due process and a fair trial; (2) the trial court erred by not instructing the jury sua sponte on defense of others; and (3) the jury’s finding that he personally and intentionally discharged a firearm proximately causing great bodily injury was not supported by substantial evidence. Both defendants argue their trial counsel rendered ineffective assistance. Chao also contends the cumulative effect of the errors he alleges necessitates reversal.2 We will affirm the judgment as to Chao. In supplemental briefing, Fernandez argues, and the People concede, he is entitled to resentencing under recent amendments to sections 654 and 1170, subdivision (b). We will accept the People’s concession and remand for resentencing with respect to Fernandez. In all other respects, we will affirm Fernandez’s convictions. I. BACKGROUND The victim testified that, on February 12, 2015, he arranged a marijuana sale at the warehouse where he was living. He was intoxicated and did not want to drive anywhere. After defendants arrived, the victim gave Fernandez the marijuana, and then both defendants pulled out semiautomatic handguns and pointed them at the victim. One of them said, “ ‘This is a jack’ ” or “ ‘This is a robbery.’ ” Chao was closer to the door and Fernandez was closer to the couch, by the victim: “I was in a direct line with Mr. Chao and Mr. Fernandez would have been off to the right a little bit.” The victim grabbed the barrel of Fernandez’s gun with his left hand and pulled it away from his face. Fernandez

2 Fernandez’s opening brief states he joins in all the arguments raised by Chao that are applicable and beneficial to him. Fernandez’s reply brief effectively clarified that this joinder applied only to Chao’s ineffective assistance of counsel claim. (See People v. Bryant, Smith and Wheeler (2014) 60 Cal.4th 335, 364 [“ ‘Joinder may be broadly permitted [citation], but each appellant has the burden of demonstrating error and prejudice’ ”].)

2 fired the gun while it was still in the victim’s hand, and then Chao started shooting the victim’s left arm. After Fernandez regained control of the gun, he started shooting at the victim too. The victim said, “[T]hey both just kept firing and shooting and trying to kill me over a stupid $300.” On the night of the shooting, law enforcement found one .40-caliber shell casing and one .25-caliber casing in the warehouse. About a month after the shooting, police officers found a .25-caliber Beretta on the floor of a car in which Chao was a passenger. The prosecution’s expert on firearm and toolmark identification opined that the .25-caliber casing that was found in the warehouse was fired from this Beretta pistol. A criminalist with the Sacramento County District Attorney’s Office, Laboratory of Forensic Services, opined that the DNA found on the magazine and trigger matched Chao’s. II. DISCUSSION A. Fernandez’s Statements to Brandon Chao argues the trial court’s admission of certain hearsay statements made by Fernandez as declarations against interest at their joint trial violated his right to due process and a fair trial. We disagree. 1. Trial Court Proceedings Prior to trial, the People moved in limine to admit statements made by Fernandez to Brandon that incriminated both defendants. The motion explained the statements at issue were non-testimonial3 and were admissible as declarations against interest. The

3 Chao concedes that the statements at issue in this case are nontestimonial. “Under the so-called Aranda/Bruton doctrine, a trial court may generally not allow a jury in a joint criminal trial of a defendant and codefendant to hear the unredacted confession of the codefendant that also directly implicates the defendant—even if the jury is instructed not to consider the confession as evidence against the defendant.” (People v. Washington (2017) 15 Cal.App.5th 19, 22-23.) Following the United States Supreme Court’s decision in Crawford v. Washington (2004) 541 U.S. 36, the Aranda/Bruton doctrine has

3 motion attached transcripts of law enforcement interviews with Brandon. At the time of the interviews, Brandon was facing charges related to a March 27, 2015 robbery. By the time he testified, he had been convicted of that robbery. During the first interview, on March 27, 2015, Brandon explained he had information about an attempted murder that occurred about a month earlier involving Fernandez, Chao, and a driver. Brandon agreed he heard about what happened from Fernandez. Brandon said Fernandez and Chao set up a person to get money or weed. Fernandez had obtained a cell phone. Chao shot the victim twice in the back, the victim fell forward, and then Fernandez shot the victim in the face. “[A]fter that then they . . . take whatever and they leave.” During the second interview, Brandon indicated he had recently learned the driver was someone else. The trial court granted the motion and admitted the statements by Fernandez to Brandon against both defendants. A portion of the first interview was introduced into evidence.4 2. Statements Against Interest “Evidence Code section 1230 sets out the hearsay exception for statements against interest: ‘Evidence of a statement by a declarant having sufficient knowledge of the subject is not made inadmissible by the hearsay rule if the declarant is unavailable as a witness and the statement, when made, was so far contrary to the declarant’s pecuniary or proprietary interest, or so far subjected him to the risk of civil or criminal liability . . . , or

no application to nontestimonial statements. (Washington, supra, at pp. 28-29.) In his reply brief, Chao suggests a recent California Supreme Court case has held otherwise “sub silentio by implication.” We disagree. People v. Holmes, McClain and Newborn (2022) 12 Cal.5th 719 never discusses whether the statements at issue were testimonial or nontestimonial and found no Aranda/Bruton error occurred. (Id. at pp. 750, 753-755.) “It is axiomatic that cases are not authority for propositions not considered.” (People v. Ault (2004) 33 Cal.4th 1250, 1268, fn. 10.) 4 The excerpt did not include Brandon’s statement that Chao hit his girlfriend with the gun because she reported him to the police. As such, we need not analyze its admissibility.

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People v. Chao CA3, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-chao-ca3-calctapp-2022.