People v. Heaps

CourtCalifornia Court of Appeal
DecidedFebruary 2, 2026
DocketB329296
StatusPublished

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

Opinion

Filed 2/2/26 CERTIFIED FOR PUBLICATION

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION ONE

THE PEOPLE, B329296

Plaintiff and Respondent, (Los Angeles County Super. Ct. No. BA484297) v.

JAMES MASON HEAPS,

Defendant and Appellant.

APPEAL from a judgment of the Superior Court of Los Angeles County, Michael D. Carter, Judge. Reversed and remanded. Alan S. Yockelson and John M. Bishop for Defendant and Appellant. Rob Bonta, Attorney General, Charles C. Ragland, Chief Assistant Attorney General, Susan Sullivan Pithey, Assistant Attorney General, Steven D. Matthews and Gary A. Lieberman, Deputy Attorneys General, for Plaintiff and Respondent. Justice Black put it simply in Gideon v. Wainwright (1963) 372 U.S. 335, in holding the Sixth Amendment’s right to counsel applies in state criminal trials: “The right of one charged with crime to counsel may not be deemed fundamental and essential to fair trials in some countries, but it is in ours.” (Id. at p. 344.) Our high court warned that right is impinged when a judge communicates with a jury during deliberations “without affording defendant and counsel an opportunity to be present . . . . [Citations.]’ [Citations.]” (People v. Hawthorne (1992) 4 Cal.4th 43, 69 (Hawthorne).) That is what happened here. Twice, the trial court, Judge Michael Carter presiding (the trial judge), sent the judicial assistant, Luis Corrales (the JA), into the jury room to speak to the jury about the foreperson’s (Juror No. 4’s) note describing the jurors’ collective concern that a juror (Juror No. 15) did not speak English sufficiently to deliberate and had already made up his mind (the Note). The JA spoke to the jury in English, and at the request of Juror No. 15, in Spanish. At no time did the trial judge inquire of the jury or inform trial counsel of the Note’s existence. The JA’s conversations about the Note with the jury were not transcribed. Respondent concedes the trial court’s handling of the Note deprived defendant of his constitutional right to counsel at a critical stage of his trial. Respondent also concedes it has the burden to prove, beyond a reasonable doubt, the absence of prejudice from this constitutional error. We conclude respondent fails to satisfy its burden to demonstrate, beyond a reasonable doubt, that the deprivation of counsel at a critical stage in the proceedings was not prejudicial. We thus reverse the judgment and remand for a new trial.

2 BACKGROUND We summarize below only those facts relevant to the dispositive issue on appeal.

1. The charges and jury findings Defendant James Mason Heaps worked as a gynecological oncologist at the University of California Los Angeles. His trial involved the claims of seven former patients for one or more of the following crimes during his medical examinations: sexual battery by fraud,1 sexual exploitation,2 and sexual penetration of

1 Penal Code section 243.4, subdivision (c) provides: “Any person who touches an intimate part of another person for the purpose of sexual arousal, sexual gratification, or sexual abuse, and the victim is at the time unconscious of the nature of the act because the perpetrator fraudulently represented that the touching served a professional purpose, is guilty of sexual battery. A violation of this subdivision is punishable by imprisonment in a county jail for not more than one year, and by a fine not exceeding two thousand dollars ($2,000); or by imprisonment in the state prison for two, three, or four years, and by a fine not exceeding ten thousand dollars ($10,000).” 2 Business and Professions Code section 729, subdivision (a) provides: “Any physician and surgeon, psychotherapist, research psychoanalyst, student research psychoanalyst, or alcohol and drug abuse counselor or any person holding themselves out to be a physician and surgeon, psychotherapist, research psychoanalyst, student research psychoanalyst, or alcohol and drug abuse counselor, who engages in an act of sexual intercourse, sodomy, oral copulation, or sexual contact with a patient or client, or with a former patient or client when the relationship was terminated primarily for the purpose of engaging in those acts, unless the physician and surgeon, psychotherapist, research psychoanalyst, student research

3 an unconscious person during gynecological examinations.3 For the counts on which the jury found defendant guilty, the jury also considered sentencing factors.

psychoanalyst, or alcohol and drug abuse counselor has referred the patient or client to an independent and objective physician and surgeon, psychotherapist, research psychoanalyst, student research psychoanalyst, or alcohol and drug abuse counselor recommended by a third-party physician and surgeon, psychotherapist, research psychoanalyst, student research psychoanalyst, or alcohol and drug abuse counselor for treatment, is guilty of sexual exploitation by a physician and surgeon, psychotherapist, research psychoanalyst, student research psychoanalyst, or alcohol and drug abuse counselor.” Business and Professions Code section 729, subdivision (b)(3) provides: “An act or acts in violation of subdivision (a) with two or more victims shall be punishable by imprisonment pursuant to subdivision (h) of Section 1170 of the Penal Code for a period of 16 months, two years, or three years, and a fine not exceeding ten thousand dollars ($10,000); or the act or acts shall be punishable by imprisonment in a county jail for a period of not more than one year, or a fine not exceeding one thousand dollars ($1,000), or by both that imprisonment and fine.” 3 Penal Code section 289, subdivision (d)(4) provides: “Any person who commits an act of sexual penetration, and the victim is at the time unconscious of the nature of the act and this is known to the person committing the act or causing the act to be committed, shall be punished by imprisonment in the state prison for three, six, or eight years. As used in this subdivision, ‘unconscious of the nature of the act’ means incapable of resisting because the victim meets one of the following conditions: [¶] . . . [¶] (4) Was not aware, knowing, perceiving, or cognizant of the essential characteristics of the act due to the perpetrator’s fraudulent representation that the sexual penetration served a professional purpose when it served no professional purpose.”

4 On October 20, 2022, the jury convicted defendant of sexual battery by fraud on N.B. The jury further found the victim was particularly vulnerable and defendant took advantage of a position of trust. The jury additionally found the crime involved separate acts of violence or threats of violence. The jury convicted defendant of two counts of sexual penetration of an unconscious person by fraudulent representation regarding J.T. The jury found J.T. was particularly vulnerable, and the crime indicated planning, sophistication, or professionalism. The jury further found defendant took advantage of a position of trust or confidence to commit the offense. The jury convicted defendant of two counts of sexual battery by fraud on J.T. The jury again found J.T. was particularly vulnerable, the crime indicated planning sophistication, or professionalism, and defendant took advantage of a position of trust or confidence to commit the offense. The jury acquitted defendant on three counts of sexual battery by fraud regarding Z.S. and L.B. The jury also acquitted defendant of three counts of sexual penetration of an unconscious person by fraudulent representation regarding Z.S. and L.B. The jury acquitted defendant on one count of sexual exploitation regarding Z.S., J.T., and L.B. The jury was unable to reach a

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