People v. Delgado CA2/6

CourtCalifornia Court of Appeal
DecidedMarch 4, 2026
DocketB337252
StatusUnpublished

This text of People v. Delgado CA2/6 (People v. Delgado CA2/6) 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. Delgado CA2/6, (Cal. Ct. App. 2026).

Opinion

Filed 3/4/26 P. v. Delgado CA2/6

NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

SECOND APPELLATE DISTRICT

DIVISION SIX

THE PEOPLE, 2d Crim. No. B337252 (Super. Ct. No. BA045767) Plaintiff and Respondent, (Los Angeles County)

v.

ADOLFO DELGADO,

Defendant and Appellant.

Adolfo Delgado appeals the denial of his motion under Penal Code1 section 1473.7 to vacate his 1991 drug conviction. We conclude the trial court improperly denied his motion as successive. We will reverse and remand with instructions. FACTUAL AND PROCEDURAL BACKGROUND On or about October 9, 1991, a complaint charged appellant with transportation, sale, or furnishing of phencyclidine (PCP) (Health & Saf. Code, § 11379.5, subd. (a)).

1 Undesignated statutory references are to the Penal Code. On October 28, 1991, appellant waived arraignment and pleaded not guilty. On November 19, 1991, appellant pleaded guilty pursuant to an agreement under which the People would ask the court to sentence appellant to a three-year “lid” and the case would proceed in a certain department. During the hearing, the prosecutor advised: “You should be informed, even though this does or does not apply to you, if you are not a citizen of the United States, that a plea of guilty to this charge could result in your deportation from the United States and your inability to become a naturalized citizen of the United States. Do you understand that?” Appellant replied, “Yes.” On January 14, 1992, the court imposed and suspended the low term of three years in state prison. The court placed appellant on formal probation for three years with 180 days in county jail as a condition of probation. On April 10, 2018, appellant filed a motion to vacate his conviction under section 1473.7. Appellant argued his counsel had been ineffective. The court held a hearing and denied the motion. On December 13, 2023, appellant filed another motion to vacate his conviction under section 1473.7. Appellant declared that he came to the United States in 1976 as a permanent resident. His wife is a citizen, and his four children were born in the United States. Three of the four children were born before appellant’s 1991 plea. According to counsel’s December 2023 declaration, appellant “was brought to ICE (Immigration and Custom Enforcement) attention in 2013 with the filing of a Notice to Appear charging him as deportable. . . . The Immigration Judge

2 denied all forms of relief, the Board of Immigration Appeals affirmed that decision, and an appeal is currently pending before the Ninth Circuit Court of Appeals.” Appellant declared his lawyer for the 1991 plea never informed him that the crime would disqualify him from remaining in the country and cause his deportation. On January 17, 2024, the court denied the motion. At the hearing, the court stated it had “received a motion. I barely reviewed it, but I don’t know that I need to review it.” The court explained that it had denied the 2018 motion and “[t]here’s no reason why this motion should be presented again. . . . So I’m inclined to deny it today’s date, based on successive and duplicative filings.” Appellant’s counsel argued a renewed motion was appropriate given the amendments to section 1473.7 and this division’s opinion in People v. Ruiz (2020) 49 Cal.App.5th 1061 (Ruiz). The court asked if counsel had reviewed the plea colloquy transcript. Counsel indicated she “pulled what [she] could” but did not have access to the transcript. The People had intended to ask for a continuance to run appellant’s rap sheet, and they had agreed with counsel on a February date. The court indicated there was no need for a continuance and that “the colloquy is clear.” The court stated: “I’m inclined to deny it, counsel. It’s successive, in this court’s opinion . . . .” The court indicated counsel should have obtained the plea transcript for the motion. The court concluded: “So it’s the same set of facts, it’s the same set of scenario, it’s the same transcript that I cannot change, and it’s in the same basis that the court based it on before. The colloquy of the plea was very clear. Denied.”

3 DISCUSSION Section 1473.7, subdivision (a)(1) authorizes a person no longer in criminal custody to file a motion to vacate a conviction or sentence that is “legally invalid due to prejudicial error damaging [their] ability to meaningfully understand, defend against, or knowingly accept the actual or potential adverse immigration consequences of a conviction or sentence.” “A successful section 1473.7 motion requires a showing, by a preponderance of the evidence, of a prejudicial error that affected the defendant’s ability to meaningfully understand the actual or potential immigration consequences of a plea.” (People v. Vivar (2021) 11 Cal.5th 510, 517.) “‘[P]rejudic[i]al error . . . means demonstrating a reasonable probability that the defendant would have rejected the plea if the defendant had correctly understood its actual or potential immigration consequences.’” (People v. Espinoza (2023) 14 Cal.5th 311, 319 (Espinoza).) To assess prejudicial error, “courts must ‘consider the totality of the circumstances.’ [Citation.] ‘Factors particularly relevant to this inquiry include the defendant’s ties to the United States, the importance the defendant placed on avoiding deportation, the defendant’s priorities in seeking a plea bargain, and whether the defendant had reason to believe an immigration- neutral negotiated disposition was possible.’ [Citations.] Also relevant are the defendant’s probability of obtaining a more favorable outcome if he had rejected the plea, as well as the difference between the bargained-for term and the likely term if he were convicted at trial.” (Espinoza, supra, 14 Cal.5th at p. 320.) “A defendant must provide ‘“‘objective evidence’”’ to corroborate factual assertions.” (Id. at p. 321.)

4 “We apply independent review to evaluate whether a defendant has demonstrated a reasonable probability that he would have rejected the plea offer had he understood its immigration consequences.” (Espinoza, supra, 14 Cal.5th at p. 319.) Under that standard, “‘“an appellate court exercises its independent judgment to determine whether the facts satisfy the rule of law.”’” (Id. at pp. 319-320.) When “the trial court’s findings ‘derive entirely from written declarations and other documents,’ the trial court and the reviewing court ‘“are in the same position,”’ and no deference is owed.” (Id. at p. 320.) The parties agree that appellant’s 2023 motion was not successive of his 2018 motion. Given the intervening amendment to section 1473.7, we agree with the parties. Effective January 1, 2019, Assembly Bill No. 2867 (2017-2018 Reg. Sess.) “made it easier to retroactively challenge convictions” based on an inadequate immigration advisement. (Ruiz, supra, 49 Cal.App.5th at p. 1066.) Significantly, the new law eliminated the need to meet the requirements of Strickland v. Washington (1984) 466 U.S. 668 [80 L.Ed.2d. 674]. (Ruiz. at pp. 1066-1067; § 1473.7, subd. (a)(1) [“finding of legal invalidity may, but need not, include a finding of ineffective assistance of counsel”].) Because the new law “provides a different standard for challenging and prevailing based on immigration advisement errors,” the 2018 motion did not bar appellant’s 2023 motion. (Ruiz, at p. 1069.) The parties dispute whether the trial court ruled on the merits.

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
People v. Watson
299 P.2d 243 (California Supreme Court, 1956)
People v. LaBlanc
238 Cal. App. 4th 1059 (California Court of Appeal, 2015)
People v. Vivar
485 P.3d 425 (California Supreme Court, 2021)

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Bluebook (online)
People v. Delgado CA2/6, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-delgado-ca26-calctapp-2026.