People v. Ferncase CA4/1

California Court of Appeal·Decided June 17, 2026·No. D084914·Unpublished

Opinion

Filed 6/17/26 P. v. Ferncase 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NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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, D084914

Plaintiff and Respondent,

v. (Super. Ct. No. SCN447507)

PATRICK JAMES FERNCASE,

Defendant and Appellant.

APPEAL from a judgment of the Superior Court of San Diego, Daniel Link, Judge. Affirmed.

Jill M. Klein, 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, Senior Assistant Attorney General, Eric A. Swenson, Supervising Deputy Attorney General and Heather B. Arambarri, Deputy Attorney General for Plaintiff and Respondent. A jury convicted Patrick James Ferncase of the December 2021 first

degree murder of Aureo Duque Rayo (Pen. Code,1 § 187, subd. (a); count 1) and the March 2022 first degree murder of Derek Baker (count 2). It found true special circumstance allegations that Ferncase was convicted of more than one first or second degree murder offense in the present proceeding

(§ 190.2, subd. (a)(3)).2 Ferncase admitted he had suffered a 2015 conviction for violating sections 245, subdivision (a)(4) and 12022.7, subdivision (b) that constituted both a prior serious felony conviction (§ 667, subd (a)) and a prior strike (§§ 667, subds. (b)-(i), 1170.12). He also admitted factors in aggravation under California Rules of Court, rules 4.421(a)(1) [offense involved great violence or bodily harm], 4.421(a)(3) [the victim was particularly vulnerable], 4.421(b)(2) [numerous prior convictions of increasing seriousness], 4.421(b)(3) [prior state and local prison term] and 4.421(b)(5) [prior unsatisfactory performance on probation]. The court sentenced Ferncase to a 10-year determinate term plus two consecutive terms of life without the possibility of parole. It imposed a $300 parole revocation restitution fine under section 1202.45. Ferncase contends the trial court prejudicially erred by failing to sever his murder charges for trial, as the offenses took place on different dates, at different places, and under different circumstances. He also contends that by permitting the prosecution to admit into evidence under Evidence Code sections 1101 and 1103 prior assaults he had committed, the court violated his rights to due process and a fair trial. Ferncase asks this court to strike his section 1202.45 parole revocation restitution fine, claiming the fine is

1 Undesignated statutory references are to the Penal Code.

2 The trial court dismissed the special allegation as to count 2. 2 inapplicable to his life-without-the-possibility-of-parole sentence. We affirm the judgment. FACTUAL AND PROCEDURAL BACKGROUND December 2021 Murder of Aureo Duque Rayo On the morning of December 22, 2021, Ferncase approached Rayo, who was working his maintenance job at a shopping center in Carlsbad. Ferncase knocked Rayo to the ground, then kicked and punched him in the head and upper torso. Surveillance video showed Ferncase stomped on Rayo 32 times over the course of a minute; witnesses described him as kicking “viciously.” The video did not show any prior interactions between Ferncase and Rayo or that they had exchanged any words before Ferncase knocked Rayo to the ground. A witness saw Ferncase “stomping” on Rayo’s lifeless body, screamed at him to stop, and called 911. She followed Ferncase in her vehicle until police arrived and arrested him. Police interviewed Ferncase after his arrest. Ferncase told a detective that Rayo, who he estimated to be 50 to 60 years old, “was talking shit,” and calling him a “white boy” so he “hit [Rayo] in the mouth, stomped him out, [and] killed him.” Ferncase told the officer, “He’s not going to live. Put twenty dollars on that. He ain’t going to make it.” Ferncase referred to Rayo as “Mexican” but explained he hit Rayo because he was “talking shit.” Rayo suffered fractures to his skull and eyes, as well as brain injury. He never regained consciousness, and died four months later from the blunt force injuries to his head. March 2022 Murder of Derek Baker On March 12, 2022, Ferncase was in the San Diego Central Jail sharing a cell with Derek Baker, a 56-year-old man with diabetes. Two inmates were housed in an adjacent cell. That day, the neighboring inmates

3 heard the distinct sound of the intercom button in the next door cell being pressed, followed by banging, grunting and the sounds of flesh impacting other flesh like a punch or physical fight. The inmates heard the intercom again and then heard a person say, “Man down.” One of the inmates identified the voice as Ferncase’s. Neither inmate heard Ferncase and Baker argue or exchange words before hearing the sounds of assault. Eventually, deputies responded to the scene. They found Baker unconscious, lying on the floor in a pool of blood. Baker was bleeding from his head and his face was so swollen he was unrecognizable. While being escorted out of the cell, Ferncase related that he “stomped [Baker] out, out of anger” saying “I was white and . . . he was Hispanic and I had to do what I had to do, or you know how it goes.” During a later

interview with detectives,3 Ferncase claimed Baker started the altercation by calling him names such as “bitch,” which were “fighting words.” Ferncase admitted to throwing the first punch, however, knocking Baker out on the second hit. According to Ferncase, Baker woke up and the men ended up on the floor where Baker tried to bite Ferncase’s genitals, but Ferncase choked him unconscious then “stomped him out.” Ferncase estimated he stomped Baker’s head about 25 times, and believed he either killed or paralyzed him. Ferncase agreed he acted in the way he did essentially because Baker was Mexican, and things in jail were race-oriented, so he had to “finish that out.” Baker suffered facial fractures and severe traumatic brain injury. He died later in March 2022 as a result of the blunt force injuries to his head. His death was ruled a homicide. Ferncase’s only injuries were a very swollen right hand/ knuckles and a scratch on his left forearm. An investigating

3 The People played Ferncase’s interview at trial and gave transcripts to jurors. 4 detective did not find, and Ferncase did not complain about, injuries to his genitals. Defense Evidence In his defense, Ferncase presented evidence that in December 2020 while at a correctional facility, a cellmate assaulted him, rendering him unconscious and leaving him with facial fractures and bleeding from his scalp. Ferncase also presented evidence about Baker, his prior arrests and aggressive behavior, as well as his medical and mental health diagnoses. The parties stipulated that Baker had pleaded guilty to sex crimes against women committed in 1984 and 1986. DISCUSSION I. Severance of Murder Charges Pointing out the charged crimes took place on different dates, at different places, and under different circumstances with different witnesses, Ferncase contends the trial court abused its discretion in denying his motion to sever the two murder counts. He maintains the facts of each case were too dissimilar to be cross-admissible, and the jury was unduly prejudiced by the inflammatory nature of Rayo’s murder, which was a stronger case. Ferncase argues the error rendered his trial fundamentally unfair in violation of his right to due process of law. A. Background Before trial, Ferncase moved to sever the two murder charges, arguing joining them would deny him due process and a fair trial.

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