People v. Henderson CA4/1

CourtCalifornia Court of Appeal
DecidedJune 2, 2026
DocketD085245
StatusUnpublished

This text of People v. Henderson CA4/1 (People v. Henderson CA4/1) 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. Henderson CA4/1, (Cal. Ct. App. 2026).

Opinion

Filed 6/2/26 P. v. Henderson CA4/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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, D085245

Plaintiff and Respondent, (Super. Ct. No. SCD299229) v.

CHARLES RAY HENDERSON,

Defendant and Appellant.

APPEAL from a judgment of the Superior Court of San Diego County, Robert O. Amador, Judge. Affirmed. Bases & Bases and Arielle Bases for Defendant and Appellant. Rob Bonta, Attorney General, Charles C. Ragland, Chief Assistant Attorney General, Arlene A. Sevidal, Assistant Attorney General, Robin Urbanski and Donald W. Ostertag, Deputy Attorneys General, for Plaintiff and Respondent. Charles Ray Henderson appeals from a judgment following his convictions on 23 counts of first degree burglary of an inhabited dwelling house in violation of Penal Code sections 459 and 460, subdivision (a), three counts of attempted first degree burglary of an inhabited dwelling house in violation of sections 459 and 664,1 one count of second degree burglary in violation of section 459, and 12 counts of conspiracy to commit a crime in violation of section 182, subdivision (a)(1). He contends his convictions should be reversed because the trial court abused its discretion by disallowing evidence that individuals not linked to him had been burglarizing homes in the same vicinity and time frame in which the offenses attributed to him had occurred, and that they had done so using modi operandi similar to those used in the charged offenses. In addition, he contends his sentence should be reversed because, in imposing it, the court did not properly consider trauma he had experienced as a child. The attorney general disagrees, and so do we. Hence we affirm. I. GENERAL BACKGROUND During the winter and spring of 2023, hundreds of burglaries and related offenses occurred throughout affluent areas of San Diego County. Among these were burglaries and attempted burglaries that occurred on: February 10, 23, and 25; March 4, 11, 13, 18, 19, 22, and 23; and May 22 and 23. Using digital location data (i.e., data pertaining to the movement of automobiles, cell phones, and other devices that communicate wirelessly with cell towers), surveillance footage, and other evidence, police placed Henderson—and, in most instances, Charelle Brumfield and Anthony Robinson—at the scene of each of these offenses. Such evidence also led police to stop a vehicle in which Henderson, Brumfield, and Robinson were traveling. At the time of the stop, no license plate was attached to the vehicle. A search of the vehicle yielded items commonly used as burglary tools, including, for example, bear spray (used in burglaries to incapacitate dogs), window punches (used to break glass),

1 All unspecified statutory references are to the Penal Code.

2 walkie talkies, screwdrivers, black gloves, black balaclavas, a grey neck gaiter, and other items of dark clothing. Subsequent searches of Henderson, Brumfield, and Robinson’s homes revealed additional such items, along with items that surveillance footage revealed the perpetrators wearing during the charged offenses and items reported stolen from homes burglarized on the dates set forth ante. Henderson, Brumfield, and Robinson were charged with conspiracy and burglary-related offenses in a 42-count information that named Henderson as a perpetrator in 41 of the counts and that alleged several aggravating factors within the meaning of the California Rules of Court, rule 4.421. The case against Robinson was severed, and the case against Henderson and Brumfield proceeded to trial. After two and a half weeks of testimony by 94 witnesses, Henderson was acquitted on two of the 41 counts against him and convicted on the other 39. The trial court then sentenced Henderson to serve a term of 38 consecutive years in state prison. Henderson timely appealed. II. THIRD PARTY CULPABILITY EVIDENCE Henderson’s first contention is that the trial court abused its discretion by disallowing evidence that crews associated with an organization dubbed the Chilean Group were believed by law enforcement authorities to have burglarized homes in the same vicinity and timeframe in which the charged offenses had occurred, and that they had used modi operandi similar to those employed in the charged offenses. A. Additional Background In pretrial motions and in an evidentiary hearing that occurred outside the presence of the jury pursuant to Evidence Code section 402 (402 hearing), the defense sought to introduce at trial, and the prosecution sought to exclude, evidence (in the form of testimony from five police officers and two

3 detectives) pertaining to a sample of six unsolved burglaries (the six uncharged burglaries) that had occurred on dates other than the dates of the charged offenses and that law enforcement authorities had attributed to the Chilean Group. As the defense argued in limine: “[A]round the time of the charged burglaries in this case, there was a similar burglary series being conducted in San Diego County by a group that SDPD Detectives referred to as ‘the Chilean Series’ . . . The ‘Chilean Series’ was apparently ‘a group of South American Nationals coming to the U.S. committing burglaries,’ throughout San Diego County. . .[2] The burglaries were occurring in the same general area and around the same time (February to May 2023) as the burglaries in the instant case . . . .

“The Defense has been provided with police reports for six individual burglary incidents that were allegedly committed by this crew that occurred from February 5, 2023-June 4, 2023. This is the same time period that the burglaries in this case allegedly occurred. The burglaries all occurred in wealthy neighborhoods in San Diego County, where rear glass doors were smashed, and high value items were stolen.

“. . . [B]urglaries . . . linked to the ‘Chilean Theft Ring’ . . . eerily resemble the incidents in this case.

“ . . . Apparently, the ‘Chilean Crew’ wears masks and hooded sweatshirts to shield their identities. . . This crew often smashed . . . rear sliding glass doors to gain entry into homes located in affluent areas and targeted cash, safes, and jewelry. These characteristics

2 According to the defense: “[T]he District Attorney for San Diego County, Summer Stephan, has made several news appearances and comments in local media regarding ‘burglary tourism.’ She has stated that people involved in these theft groups ‘travel to the United States through the ESTA Visa Waiver Program,’ which allows them to fill out a quick online questionnaire and receive a 90-day tourist Visa. They then use fraudulent identification or driver’s licenses to rent cars to conduct the burglaries.”

4 are identical to the allegations in this case. As such, the Defense should be able to raise this information to the Jury because it creates a doubt as to the identity of the actual burglars.”

The trial court disagreed. Thus it disallowed evidence pertaining to the Chilean Group and to the six uncharged burglaries noted ante. But it permitted the defense to elicit evidence, and to argue to the jury, that several different burglary crews had been operating in the same communities and timeframe in which the charged offenses had occurred and that these crews had used modi operandi similar to those used in the charged offenses. B.

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Bluebook (online)
People v. Henderson CA4/1, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-henderson-ca41-calctapp-2026.