People v. Gutierrez

CourtCalifornia Court of Appeal
DecidedFebruary 17, 2026
DocketD086351
StatusPublished

This text of People v. Gutierrez (People v. Gutierrez) 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. Gutierrez, (Cal. Ct. App. 2026).

Opinion

Filed 2/17/26 CERTIFIED FOR PUBLICATION

COURT OF APPEAL, FOURTH APPELLATE DISTRICT

DIVISION ONE

STATE OF CALIFORNIA

THE PEOPLE, D086351

Plaintiff and Respondent,

v. (Super. Ct. No. SWF2301890)

DEREK J. GUTIERREZ,

Defendant and Appellant.

APPEAL from a judgment of the Superior Court of Riverside County, Louis R. Hanoian, Judge. Reversed and remanded. Brad J. Poore, under appointment by the Court of Appeal, for Defendant and Appellant. Rob Bonta, Attorney General, Lance E. Winters, Chief Assistant Attorney General, Charles C. Ragland, Assistant Attorney General, Steve Oetting and Maxine Hart, Deputy Attorneys General, for Plaintiff and Respondent. INTRODUCTION In October 2015, Governor Edmund Gerald Brown Jr. declared a state of emergency in California due to “Tree Mortality.” Record drought conditions over four years had caused epidemic infestations of native bark beetles. According to the United States Forest Service, the infestations caused the death of more than 22 million trees, with the death of 10 million more yet to come. The proclamation establishing the state of emergency warned “this die-off is of such scale that it worsens wildfire risk across large regions of the State, presents life safety risks from falling trees to Californians living in impacted rural, forested communities, and worsens the threat of erosion across watersheds.” The proclamation directed four state agencies to immediately identify “areas of the [s]tate” that represent “high hazard zones” for wildfire and falling trees “using [the] best available science and geospatial data.” Eight years later, in 2023, the state of emergency was still ongoing. In December 2023, Derek J. Gutierrez was arrested for setting a fire in Riverside County near what the parties and witnesses refer to as the Ortega Mountains. A jury convicted him of felony arson of forest land and found true a sentencing enhancement allegation that he set the fire “during and within an area” proclaimed by the Governor to be in a state of emergency. (Pen. Code, § 454, subd. (a)(2).) The enhancement elevates the sentencing triad for this type of arson by five, seven, or nine years. The additional punishment is warranted for obvious policy reasons, given the continual state of drought, wildfire, and other risk of disaster in our state. In the words of the trial court, “Arson of forest land is incredibly dangerous. In this part of the world, to set a fire in the wildlands is beyond irresponsible.” The parties here dispute whether the tree mortality state of emergency declared by Governor Brown extended statewide generally—that is, throughout the entire territorial jurisdiction of California—or whether it existed only in specific areas and zones of California determined to have been impacted by bark beetle infestation. As we explain, this question is one that

2 should have been resolved by the trial court below, but it was not. It was instead left for the jury to resolve. This was error because the interpretation of the Governor’s proclamation is a purely legal question; it is not a question for the jury. Based on our independent review of Governor Brown’s proclamation, we agree with Gutierrez that the tree mortality state of emergency did not extend statewide. As a result, we are compelled to reverse the jury’s true finding on the state of emergency enhancement allegation for insubstantial evidence. As we interpret the proclamation, it existed only in certain very specific areas of the state, and the People failed to meet their burden of identifying those areas for the jury and proving Gutierrez set a fire in one of them. We reject Gutierrez’s other claims of error and so we (1) affirm his underlying conviction for arson of forest land, (2) remand for a full resentencing, and (3) if Gutierrez requests, direct the trial court to conduct a hearing to determine whether he has the ability to pay fines and ancillary costs under the guidance of our high court’s recent decision, People v. Kopp (2025) 19 Cal.5th 1 (Kopp). PROCEDURAL AND FACTUAL BACKGROUND I. Prosecution Case In 2023, Jorge L. lived in Riverside County near the Ortega Mountains. The property had four or five buildings on about eight acres of land. It was “rural in the back and . . . next to a big hill.” On December 9, 2023, around 6:30 a.m., Jorge heard “yelling and screaming” outside. He drove up the hill to investigate. He stopped the truck near some bushes about halfway between his house and the mountains.

3 Gutierrez came out of the bushes wearing a backpack. He was about 100 or 200 feet from Jorge. Jorge recognized him because, about a year earlier, he had seen the owner of the property tell Gutierrez to leave the property and never come back. Jorge asked Gutierrez what he was doing, and Gutierrez asked him for a beer. Jorge took a photograph of Gutierrez and told him he had no beer. Gutierrez went back into the bushes, and Jorge could no longer see him. A few minutes later, Jorge saw smoke coming from the bushes. He called the property owner, then 911. While Jorge was on the phone reporting the smoke to the 911 dispatcher, Gutierrez began walking down the hill while “yelling, and saying something.” Firefighters from the Riverside County Fire Department arrived within 15 to 20 minutes. A fire captain noticed smoke as he approached. He saw a person standing near the location of the smoke. The person started walking down the hill through the forest toward Lakeland Village. The captain later identified the person as Gutierrez. Jorge walked with the fire captain to the area where he had seen the smoke. When they got there, it looked to Jorge like there had been a fire, but someone put dirt on it to try and put it out. He could see “little ashes” and “embers,” and the material was still smoking. The firefighters smothered the smoking material and then used water to cool it down. Based on his experience and training, the fire captain believed there had been a fire and it had been set intentionally and maliciously, not by accident. The material used as tinder to start the fire was different than the surrounding vegetation, and it appeared to have been deliberately arranged “to facilitate combustion” in a way that “would spread fire to any adjacent wood in the area.” The fire was set near brush and “ladder fuels,” meaning

4 surface fuels on the ground that would “ladder” the fire to “aerial fuels” on the top of the trees. The fire did not appear to be intended for cooking because “[t]here were no utensils, no pots, no pans, and no specific border around the fire to maintain control of that fire.” As a result, there was nothing to ensure the fire would “be fixed in one location for cooking.” For example, there was no circle of rocks set up to keep the fire from escaping. That afternoon, around 2:00 or 3:00 p.m., a fire investigator with the Department of Forestry and Fire Protection (CAL FIRE) was dispatched to investigate the fire. On his way, he saw a man walking on Grand Avenue in Lakeland Village about a mile and a half from the property. The man was smoking a cigarette. The investigator stopped, spoke with the man, and took a picture of him. He asked the man if he had any lighters, and the man showed him he had one. The man was carrying a backpack and a grocery bag. The fire investigator continued on his way to interview Jorge and then walked with him to where he had seen the smoke and the remains of the fire. Jorge showed him the picture of Gutierrez. The investigator recognized Gutierrez as the person he had just seen and spoken to on Grand Avenue, and noticed he was wearing the same clothes. The fire investigator observed the fire had been set in a very secluded area on a slope near the Ortega Mountains. He searched for evidence of accidental ignition sources for the fire, such as fireworks or evidence that someone had been smoking. He found none.

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Bluebook (online)
People v. Gutierrez, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-gutierrez-calctapp-2026.