People v. Giddens

CourtCalifornia Court of Appeal
DecidedNovember 30, 2021
DocketE073390
StatusPublished

This text of People v. Giddens (People v. Giddens) 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. Giddens, (Cal. Ct. App. 2021).

Opinion

Filed 11/5/21; Modified and certified for publication 11/30/21 (order attached)

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FOURTH APPELLATE DISTRICT

DIVISION TWO

THE PEOPLE,

Plaintiff and Respondent, E073390

v. (Super.Ct.No. FWV18004475)

CHELSEA TAYLOR GIDDENS, OPINION

Defendant and Appellant.

APPEAL from the Superior Court of San Bernardino County. Ingrid Adamson

Uhler, Judge. Affirmed.

Taylor L. Clark, under appointment by the Court of Appeal, for Defendant and

Appellant.

Xavier Becerra, Attorney General, Lance E. Winters, Chief Assistant Attorney

General, Julie L. Garland, Assistant Attorney General, Eric A. Swenson and Junichi P.

Semitsu, Deputy Attorneys General for Plaintiff and Respondent.

1 While an inmate at West Valley Detention Center, defendant Chelsea Giddens

threw a milk carton filled with urine at a deputy, hitting her in the face. As a result of the

incident, which was recorded by one of the jail’s security cameras, the prosecution

charged Giddens with one count of “gassing” a peace officer (Pen. Code, § 243.9), an

aggravated form of battery that occurs when an inmate intentionally causes “any mixture

containing human excrement or other bodily fluids” to make contact with the officer’s

“skin or membranes.” (Pen. Code, § 243.9, subd. (b), unlabeled statutory citations refer to

this code.)

At trial, the prosecution played the security footage for the jury, and the deputy

testified she was certain the “salty, warm” liquid that splashed into her eyes and mouth

was urine. Giddens testified in her own defense and denied throwing anything at the

deputy, but her attorney presented a different theory during closing statements, arguing

the prosecution had failed to prove beyond a reasonable doubt the liquid was urine as it

was just as likely Giddens had made a concoction of warm water and rotting food from

her cell. The jury found Giddens guilty as charged.

On appeal, she asserts the following three grounds for reversing her conviction:

(1) the jail violated section 243.9’s mandatory duty to collect a sample of the suspected

gassing substance and test it to determine whether it in fact contains a bodily fluid; (2) the

failure to test the contents of the liquid also violated her due process rights to the

disclosure of potentially exculpatory evidence; and (3) the trial judge erroneously denied

2 her section 1118.1 motion to dismiss the gassing charge for insufficient evidence. We

disagree on each point and affirm.

I

FACTS

At West Valley Detention Center in Rancho Cucamonga, inmates receive their

meals on styrofoam trays delivered through a foot-wide “tray slot” in the center of their

cell doors. The jail employs a tray-for-tray mealtime policy, for sanitary reasons. To

receive the current meal, inmates must pass the spent trays from their previous meal

through the slot so they may be disposed of and don’t remain in the cells for extended

periods of time. On August 17, 2018, San Bernardino County Sheriff’s Deputy Jenna Van

Leer was on lunch duty in Giddens’s unit delivering trays of food. When she reached

Giddens’s cell, Deputy Van Leer could see through the window in her door that Giddens

had taken off her pants and was wearing only her shirt and underwear and that she had

multiple spent trays stacked in her cell.

Deputy Van Leer opened the tray slot in Giddens’s door and asked for her spent

trays. Giddens refused to hand them over, so Deputy Van Leer finished serving the rest of

the unit before returning to Giddens’s cell. As Deputy Van Leer served the others,

Giddens started throwing her spent trays out of her tray slot. When Deputy Van Leer

returned, Giddens pushed her hands through the slot and demanded her lunch. Deputy

Van Leer asked Giddens to remove her hands from the slot. She refused and she pushed

back against the slot as Deputy Van Leer tried to close it. Deputy Van Leer told Giddens

3 she would give her the meal (which consisted of two trays) if she removed her hands, and

Giddens complied. But as the deputy bent down to give her the trays, Giddens ran to the

back of her cell and grabbed an eight-ounce milk carton. The carton had been completely

unsealed and opened at the top so it resembled a square cup. Giddens hurled the carton at

Deputy Van Leer. When it hit the cell door, some of its contents splashed through the

opening between the frame and the door and hit the deputy’s face and hair. As she wiped

the liquid off her face with her sleeve, Giddens said angrily, “You should have given me

my trays the first time, cunt,” then laughed.

Deputy Van Leer called her partner, Deputy Tyler Gilbert, for assistance, and

when he learned what had happened he took her to the hospital where she received blood

tests to determine whether she had contracted any infections from the incident. When

Deputy Gilbert returned to Giddens’s cell about 15 minutes later to remove her, he found

Giddens nude and wet. She had flooded her cell by clogging her toilet, and she had

smeared feces on her tray slot. Deputy Gilbert also noticed feces on Giddens’s hands

when she slid them through the slot to be handcuffed.

At trial, the prosecution played the surveillance footage of Deputy Van Leer

delivering lunch to the unit. The second time she stops at Giddens’s cell, you see her

bend down to slide the trays through the slot then jump back and wipe her face with her

sleeve. Deputy Van Leer told the jury that as soon as the liquid dripped into her mouth,

she knew it was urine. She said it was warm, salty, and clear, and neither tasted nor

looked like any of the beverages served to inmates (a limited list consisting of just milk,

4 water, coffee, and Kool-Aid). She said while she doesn’t “go around tasting urine,” she

used to be an emergency medical technician (EMT), an occupation that involved frequent

close contact with the bodily fluid. She said she had “been peed on” multiple times as an

EMT. “It’s part of the job.”

When asked if the jail had tested the liquid to determine whether it was, in fact,

urine, Deputy Van Leer said she wasn’t sure if such testing was available, and in any

event, there wasn’t enough of the liquid on her or the floor to collect a sample. During

cross-examination, defense counsel asked her why she had described it as an “unknown

liquid” in her incident report if she was certain it was urine. She explained she had

wanted to call the liquid urine, but her sergeant instructed her not to, despite the fact she

was “a hundred percent sure” what it was.

Echoing Deputy Van Leer, Deputy Gilbert said it would have been impossible to

collect a sample of the liquid by the time he reached Giddens’s cell because Giddens had

flooded it. He had similarly described the substance as an “unknown liquid” in his

incident report but added that it “appeared to be urine.”

Giddens testified in her own defense and denied ever having thrown “anything,

any date, any year, at anyone.” When asked about the surveillance footage, she said, “I

did not see anything on the surveillance video. I don’t even believe that was even me to

tell you the truth.” She said the person in the video was actually “a woman named Mary”

and that she felt bad for Mary because Deputy Van Leer wasn’t feeding her. She also

denied smearing feces on her tray slot. She said the brown substance Deputy Gilbert

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People v. Giddens, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-giddens-calctapp-2021.