People v. Contreras CA4/1

CourtCalifornia Court of Appeal
DecidedJuly 8, 2026
DocketD086165
StatusUnpublished

This text of People v. Contreras CA4/1 (People v. Contreras 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. Contreras CA4/1, (Cal. Ct. App. 2026).

Opinion

Filed 7/8/26 P. v. Contreras CA4/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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, D086165

Plaintiff and Respondent, (Super. Ct. Nos. RIF2200365, RIF2100573, RIF2205377, v. RIM2200393, RIM2202026

EDWARD CONTRERAS,

Defendant and Appellant.

APPEAL from a judgment of the Superior Court of Riverside County, Jennifer Gerard, Judge. Affirmed. Sheila O’Connor, under appointment by the Court of Appeal, for Defendant and Appellant. Rob Bonta, Attorney General, Charles C. Ragland, Chief Assistant Attorney General, Arlene A. Sevidal, Assistant Attorney General, A. Natasha Cortina and Genevieve Herbert, Deputy Attorneys General, for Plaintiff and Respondent.

I. INTRODUCTION Edward Contreras pled guilty to kidnapping, second-degree burglary, identity theft, and two counts of petty theft. He also admitted certain enhancements. The trial judge sentenced Contreras to 12 years in prison. On appeal, Contreras argues the trial court abused its discretion by denying his motion for a continuance on the day of sentencing so he could explore withdrawing his guilty pleas. Finding no error, we affirm. II. FACTUAL AND PROCEDURAL BACKGROUND Between 2020 and 2022, the People charged Contreras with six felonies and four misdemeanors in five separate cases. Because Contreras had prior strike offenses, he faced a potential sentence for all cases combined of roughly 34 years to life. Contreras initially pled not guilty in each case. An extended pre-trial period ensued, during which Contreras made

three Marsden1 motions to relieve his court-appointed counsel and obtained at least five continuances. At various points during this time, Contreras also retained three different attorneys to represent him. On September 10, 2024, Contreras, represented by retained counsel, entered guilty pleas in all five cases. In case No. RIF2200365, Contreras pled

guilty to kidnapping (Pen. Code § 207, subd. (a))2 and admitted to a strike prior (§§ 667, subds. (c) & (e); 1170.12, subd. (c)), and an out-on-bail enhancement (§ 12022.1). In case No. RIF2100573, Contreras pled guilty to second-degree burglary (§ 459). And, in case Nos. RIF2205377, RIM2200393, and RIM2202026, Contreras pled guilty, respectively, to identity theft (§ 530.5, subd. (a)) and two petty theft counts (§ 488). The court scheduled sentencing for September 25, 2024. On that date, at the request of the defense, the court continued sentencing to

1 People v. Marsden (1970) 2 Cal.3d 118.

2 All undesignated statutory references are to the Penal Code.

2 December 6, 2024. When the December hearing arrived, the court continued sentencing to February 28, 2025, again at the defense’s request. Contreras, who was present at both hearings, personally confirmed that the new sentencing dates were either “timely” or “fine.” At the February hearing, Contreras, through yet a different counsel, sought removal of his attorney. Contreras personally confirmed that desire, and the trial court appointed counsel who had asked for removal on Contreras’s behalf. The court then inquired whether defense counsel wanted to put anything on the record before sentencing. Counsel responded, “I would like to put on the record that Mr. Contreras’[s] request from the Court is to withdraw his plea. With that, the conflict panel would need time to prepare that motion” and “there are various issues that he believes would be founded a motion to withdraw [sic].” The trial court denied Contreras’s request. It found “good cause” did not exist “to prevent the sentencing from occurring at this time,” noting Contreras’s case had been “set over several times.” The trial court sentenced Contreras to 12 years in prison for kidnapping, to run concurrently with a three-year term for second-degree burglary, nine days for identity theft, and time served for the petty thefts. III. DISCUSSION Contreras argues the trial court abused its discretion by denying his request to continue sentencing so he could prepare a motion to withdraw his guilty pleas, thereby depriving him of due process and effective assistance of counsel. In response, the People contend Contreras failed to show good cause for a continuance. We agree with the People. In a criminal case, a continuance may only be granted upon a showing of “good cause.” (§ 1050, subd. (e).) A trial court has wide discretion in

3 determining whether good cause exists. (People v. Beames (2007) 40 Cal.4th 907, 920 (Beames).) In making that determination, trial courts consider “ ‘ “ ‘not only the benefit which the moving party anticipates but also the likelihood that such benefit will result, the burden on other witnesses, jurors and the court and, above all, whether substantial justice will be accomplished or defeated by a granting of the motion.’ ” ’ ” (People v. Doolin (2009) 45 Cal.4th 390, 450 (Doolin).) A showing of good cause also requires that both counsel and the defendant have acted with due diligence (People v. Jenkins (2000) 22 Cal.4th 900, 1037 (Jenkins)), but the trial court may not exercise its discretion “ ‘so as to deprive the defendant or his attorney of a reasonable opportunity to prepare.’ ” (Doolin, at p. 450.) We review a court’s decision on a motion for a continuance for an abuse of discretion. “ ‘There are no mechanical tests for deciding when a denial of a continuance is so arbitrary as to violate due process. The answer must be found in the circumstances present in every case, particularly in the reasons presented to the trial judge at the time the request is denied.’ ” (People v. Mungia (2008) 44 Cal.4th 1101, 1118 (Mungia).) A trial court’s “discretion is abused only when the court exceeds the bounds of reason, all circumstances being considered.” (Beames, supra, 40 Cal.4th at p. 920.) “In the absence of a showing of an abuse of discretion and prejudice to the defendant, a denial of his or her motion for a continuance does not require reversal.” (People v. Samayoa (1997) 15 Cal.4th 795, 840; accord Beames, at p. 920 [“[A]n order denying a continuance is seldom successfully attacked.”].) Here, Contreras did not explain to the trial court, and fails to explain to us, why he should be permitted to withdraw his guilty pleas. “ ‘[M]istake, ignorance, fraud, duress or any other factor that overcomes the exercise of free judgment’ ” constitute good cause to withdraw a guilty plea. (People v.

4 Dillard (2017) 8 Cal.App.5th 657, 665.) But “[a] plea may not be withdrawn simply because a defendant has changed his or her mind.” (Ibid.) Although counsel stated Contreras had “various issues” on which a motion to withdraw would be “founded,” counsel did not expound upon these ”issues,” let alone explain what evidence he anticipated would support the motion. Such a general assertion based on vague promises of evidence to support a plea withdrawal falls short of demonstrating that a continuance would affect the outcome of the proceedings to Contreras’s benefit. (See Jenkins, supra, 22 Cal.4th at p. 1038 [no abuse of discretion in denying continuance when defendant had not demonstrated continuance would be useful in producing specific relevant mitigating evidence]; Mungia, supra, 44 Cal.4th at p. 1118 [“In reviewing the decision to deny a continuance, ‘[o]ne factor to consider is whether a continuance would be useful.’ ”].) Moreover, without such explanation, there is no basis to conclude that Contreras and his counsel were reasonably diligent with respect to the proposed motion.

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. Marsden
465 P.2d 44 (California Supreme Court, 1970)
People v. Jenkins
997 P.2d 1044 (California Supreme Court, 2000)
People v. Watson
299 P.2d 243 (California Supreme Court, 1956)
People v. Jeffers
188 Cal. App. 3d 840 (California Court of Appeal, 1987)
People v. Fontana
139 Cal. App. 3d 326 (California Court of Appeal, 1982)
Oliveros v. County of Los Angeles
16 Cal. Rptr. 3d 638 (California Court of Appeal, 2004)
People v. Beames
153 P.3d 955 (California Supreme Court, 2007)
People v. Dillard
8 Cal. App. 5th 657 (California Court of Appeal, 2017)
People v. Samayoa
938 P.2d 2 (California Supreme Court, 1997)
People v. Stowell
79 P.3d 1030 (California Supreme Court, 2003)
People v. Mungia
189 P.3d 880 (California Supreme Court, 2008)
People v. Doolin
198 P.3d 11 (California Supreme Court, 2009)

Cite This Page — Counsel Stack

Bluebook (online)
People v. Contreras CA4/1, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-contreras-ca41-calctapp-2026.