People v. Espinosa

California Court of Appeal·Decided August 31, 2026·No. E085176·Published

Opinion

Filed 8/31/26

CERTIFIED FOR PUBLICATION

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA FOURTH APPELLATE DISTRICT DIVISION TWO

THE PEOPLE, Plaintiff and Appellant, E085176 v. (Super.Ct.No. SWF029405) OSCAR ENRIQUE ESPINOSA, OPINION Defendant and Respondent.

APPEAL from the Superior Court of Riverside County. Jeffrey M. Zimel, Judge.

Affirmed with directions.

Michael Hestrin, District Attorney, W. Matthew Murray, Deputy District Attorney for Plaintiff and Appellant.

Laura Arnold under appointment by the Court of Appeal, for Defendant and Respondent.

The Department of Corrections and Rehabilitation (the Department)

recommended to the trial court that it hold a hearing to consider compassionate release

for defendant and respondent Oscar Enrique Espinosa. (Pen. Code, § 1172.2, subd. (a).) 1 The trial court conducted a hearing and recalled defendant’s prison sentence.

Plaintiffs and appellants the People of the State of California raise five issues on appeal. First, the People contend the trial court erred by admitting hearsay regarding defendant’s medical conditions. Second, the People assert the trial court erred by allowing online testimony without the People’s consent. Third, the People contend the trial court erred by not resentencing defendant after recalling his prison sentence. Fourth, the People assert there is a clerical error in a minute order. Fifth, the People contend the trial court erred by not imposing mandatory parole conditions. We affirm with directions.

FACTUAL AND PROCEDURAL HISTORY A. CONVICTIONS AND SENTENCE Defendant was 75 years old when he committed his crimes in September 2009.

Defendant was convicted on three counts: (A) one count of engaging in sexual intercourse or sodomy with a child who is 10 years old or younger (§ 288.7, subd. (a)); and (B) two counts of committing a lewd or lascivious act upon a child who is younger than 14 years old (§ 288, subd. (a)). In 2010, the trial court sentenced defendant to prison for a determinate term of 10 years and a consecutive indeterminate term of 25 years to life.

1 All subsequent statutory references will be to the Penal Code unless otherwise indicated.

B. MEDICAL PAROLE In January 2023, defendant was released from custody on medical parole. 2 (§ 3550, subd. (a).) A defendant may be medically paroled if he is “permanently unable to perform activities of basic daily living.” (§ 3550, subd. (a).) As part of releasing a defendant on medical parole, the Department must “ensure that the prisoner has applied for any federal entitlement programs for which the prisoner is eligible.” (§ 3550, subd. (i); see also § 2065, subd. (c)(5)(A).) Federal entitlement programs include Medicare. (42 U.S.C.A. §§ 426, 1395c, 1395k; Florida Ass’n of Rehabilitation Facilities, Inc. v. State of Fla. Dept. of Health and Rehabilitative Services (2000 11th Cir.) 225 F.3d 1208, 1211.)

Upon his release, defendant began residing in a privately owned, noncustodial, long-term care facility (the Facility). Despite the statutory requirement that the Department ensure a Medicare application be filed for defendant, defendant remained on the Department’s insurance. In other words, the Department funded defendant’s stay at the Facility.

C. THE DEPARTMENT’S LETTER In November 2024, the Department sent the trial court a letter recommending compassionate release for defendant because he was “permanently medically

2 Unlike compassionate release, medical parole is conditional. If a defendant on medical parole happens to recover from their medical ailment, then the defendant can be returned to prison. (§ 3550, subd. (h).) By contrast, defendants granted compassionate release are “resentence[d] ... to serve their sentences outside prison.” (People v. Loper (2015) 60 Cal.4th 1155, 1160 (Loper).)

incapacitated.” The Department’s letter represented that defendant was 90 years old and had been residing in the Facility since January 2023. Defendant required assistance with feeding, bathing, dressing, using the restroom, and moving from the bed to a chair. The Department explained that defendant “had a stroke which resulted in significant weakness” and he was suffering from dementia.

A report of defendant’s recent medical history (the Report), was included with the letter. The Report was signed by two doctors employed by the Department: (1) Thomas Bui, M.D., Physician and Surgeon, and (2) Michele DiTomas, M.D., Assistant Deputy Medical Executive.

A packet of documents was attached to the Report. The packet included a postrelease plan for defendant, which states in its entirety: “Should [defendant] receive a[] recall of sentence, he will be supported in completing [an] application for Medi-Cal and other social services and discharged to a supportive setting that can meet his medical needs.” According to the People, the Department was seeking compassionate release for defendant because the Department’s contract with the Facility was ending.3

3 On appeal, the People contend that “releasing [defendant] presents significant cost savings for [the Department].” We presume the Department sought compassionate release for defendant because the Department had failed to apply for Medicare for defendant when he was released on medical parole (§§ 2065, subd. (c), 3550, subd. (i)), which resulted in the Department continuing to pay for defendant’s care, and it no longer wanted to pay for his care. (People v. Multani (2024) 106 Cal.App.5th 1334, 1346-1347 [“[S]aving on health care costs in prisons was a legislative purpose of the statute enacting the original compassionate release provisions in 1997, and of a 2007 amendment that extended eligibility to medically incapacitated prisoners”].)

D. OPPOSITION The People opposed compassionate release for defendant. The People asserted the Report was replete with hearsay. The People attacked the Report for failing to identify the original source of the medical history conveyed by Dr. Bui. For example, the Report did not indicate whether Dr. Bui examined defendant or read defendant’s medical charts. The People contended compassionate release should be denied because defendant failed to meet his burden of demonstrating, with admissible evidence, that he meets the medical criteria for compassionate release. The trial court overruled the People’s hearsay objection.

E. HEARING 1. TESTIMONY

Dr. Faiza Rading (Rading) is a physician employed by the Department; she testified at defendant’s compassionate release hearing. Rading is the chief of palliative care in the Sacramento area. Palliative care is “care that is given to patients who have chronic serious illnesses.” Rading reviewed defendant’s medical records and records from the Facility, but she did not examine defendant. Department doctors do not have privileges to examine patients in the Facility.

Over the People’s ongoing hearsay objection, Rading testified that defendant suffered a stroke and was diagnosed with advanced dementia. Rading further testified, “I can say that from my discussion with the nursing staff, his movement is pretty limited. He needs a lot of assistance.” When asked for more detail, Rading explained, “So according to my discussion with nursing, he—when he’s getting out of bed and into

his chair, he needs assistance because his legs can fail and he’s frail. He needs assistance with dressing. He needs assistance with shower[ing]. He can use a walker, but he needs somebody to assist him. And when he’s in a wheelchair, he needs an attendant to push him around in his wheelchair. [¶] He also—he can feed himself, but he needs assistance with getting the food set up for him and also prompting ... you really need to prompt him ... for him to accomplish [activities].”

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