People v. Hughes CA5

CourtCalifornia Court of Appeal
DecidedAugust 22, 2024
DocketF085448
StatusUnpublished

This text of People v. Hughes CA5 (People v. Hughes CA5) 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. Hughes CA5, (Cal. Ct. App. 2024).

Opinion

Filed 8/22/24 P. v. Hughes CA5

NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIFTH APPELLATE DISTRICT

THE PEOPLE, F085448 Plaintiff and Respondent, (Super. Ct. No. VCF358027) v.

JOSEPH ALLEN HUGHES, OPINION Defendant and Appellant.

APPEAL from a judgment of the Superior Court of Tulare County. Nathan G. Leedy, Judge. Mark David Greenberg, under appointment by the Court of Appeal, for Defendant and Appellant. Rob Bonta, Attorney General, Lance E. Winters, Chief Assistant Attorney General, Michael P. Farrell, Assistant Attorney General, Louis M. Vasquez, Amanda D. Cary, Lewis A. Martinez, and Hannah Janigian Chavez, Deputy Attorneys General, for Plaintiff and Respondent. -ooOoo- In 2006, defendant Joseph Allen Hughes (Hughes) killed his wife, Sonia Hughes (Sonia). On November 18, 2022, Hughes was convicted of second degree murder. On appeal, Hughes argues that the conviction must be reversed because the evidence only supported a finding of heat-of-passion manslaughter. The People disagree. We reviewed the record and determined there was an issue regarding the trial court’s ruling on Hughes’s first motion for acquittal. Accordingly, we directed the parties “to file supplemental briefs addressing the following issues: (1) Did the trial court apply the wrong legal standard when it denied [Hughes’s] Penal Code section 1118[1] motion after the prosecution’s case-in-chief? (2) If the trial court applied the wrong standard, was the error harmless? (3) If the trial court erred and the error was not harmless, what is the appropriate remedy?” In their supplemental briefing, the parties agree that there was error but disagree as to whether the error was harmless and the appropriate remedy. Substantial evidence supports the conviction. However, we conditionally reverse the judgment and remand with directions for the trial court to reconsider Hughes’s first section 1118 motion using the correct standard. PROCEDURAL HISTORY On October 28, 2022, the Tulare County District Attorney filed an amended information charging Hughes with the murder of Sonia Hughes (§ 187, subd. (a); count 1). Hughes waived his right to a jury trial, and a court trial was held. After the prosecution’s case-in-chief, Hughes made an oral motion for acquittal pursuant to section 1118. The motion was denied. Hughes then waived the statute of limitations for

1 All further undesignated statutory references are to the Penal Code.

2. voluntary manslaughter. After Hughes rested, he renewed his motion for acquittal. The motion was denied. On November 18, 2022, the trial court found Hughes guilty of second degree murder. On December 16, 2022, the trial court sentenced Hughes to 15 years to life. On December 16, 2022, Hughes filed a notice of appeal. FACTUAL SUMMARY The Prosecution’s Case On November 25, 2006, Sonia’s partially buried remains were discovered on the bank of a dry creek. The Tulare County Sheriff’s Office excavated Sonia’s remains. A detective with the sheriff’s office found that pajama bottoms were tied in a knot around Sonia’s neck, although he was unable to determine how tightly it had been tied. On November 30, 2006, Curtis Brown, a detective with the Visalia Police Department, went to Hughes’s house. Brown informed Hughes that his wife’s remains were found. Hughes did not show any emotion. Hughes told Brown that his wife left with a black bag and a white plastic bag about a week and a half after Hughes got out of jail. He had last seen her around October 1, 2006. He believed that his wife was with a man named S.R., and that his wife was in a relationship with this man. Hughes also told Brown that he was aware of potential infidelity while he was in jail, but he and Sonia were still married and had agreed to remain friends for the kids. After he got out of jail, he and Sonia started getting along, remained intimate, and were attempting to work on their issues. However, Sonia was heavily using narcotics and wanted Hughes to do drugs with her. She had also sold items from Hughes’s house. Hughes also told Brown that he talked to the police about his wife leaving around five days after she left. Brown reviewed Visalia Police Department records and

3. confirmed that on October 6, 2006, Hughes placed a call for service and police went to his house. Hughes also told Brown that he had a live-in girlfriend, and that they had been together for a few weeks. On December 1, 2006, Brown searched Hughes’s residence. Brown seized a shoebox full of documents. One of the documents was a letter postmarked September 26, 2006. Hughes wrote the letter to Sonia while he was still in jail. Hughes wrote, “Here’s your bracelet, Sonia. No reason for me to wear it …, you don’t love me.” Brown also located a burn barrel. There was no fire, but there was ash inside, as well as items that had not been completely burned. Brown located women’s clothing, as well as what looked like wedding photographs with Sonia and Hughes. On or around February 20, 2016, one of Hughes’s sons, Doe 1, came into the police station to provide a statement. Doe 1 first provided his statement to Officer Lamar. On February 22, 2016, Doe 1 provided his statement to Celestina Sanchez, a detective with the Visalia Police Department. After receiving the statement, Sanchez began conducting further investigations. On March 1, 2016, Sanchez interviewed Hughes. Hughes “was very angry,” and he stated that he also wanted to know who murdered Sonia. Sanchez asked Hughes if he would give a statement, and Hughes told her that he would only tell her the story once. Hughes told Sanchez that, while he was in jail, he was informed that Sonia was using narcotics and being unfaithful. So, he sent word to Sonia telling her to stop. After he was released, he went home. He saw that Sonia was wearing short skirts and high heels. Hughes believed she was doing this because she was using narcotics, and possibly because she was prostituting herself and spending time with prostitutes. Hughes also told Sanchez that a black man and a black woman came to his residence. They had a conversation with Sonia. Sonia then asked Hughes to do some

4. side work to make money. Hughes believed Sonia wanted the money for narcotics, and Sonia got upset when Hughes was not able to make as much money as Sonia wanted. Sonia left and never returned. Hughes believed that Sonia had left with the black man and black woman. Sanchez did not tell Hughes that Doe 1 had made a statement. However, as Sanchez continued investigating, Sonia’s sister, G.G., provided Sanchez with a letter written by Hughes to one of his daughters, Doe 2. The letter included an envelope, which was postmarked August 22, 2016. The letter mentioned that Doe 1 had come forward with an additional piece of information. Sonia’s sister, G.G., testified at trial. According to G.G., after she found out that Sonia was no longer at Hughes’s residence, she talked to Hughes. Hughes told her that Sonia had left with someone because Hughes found out what Sonia was doing while he was in jail. G.G. also testified that Hughes told her he had cheated on Sonia, and that Sonia had found out. Hughes’s son, Doe 1, testified at trial. He was 12 at the time of the incident. According to Doe 1, Hughes was released from jail in September of 2006. Hughes came home in the evening. Sonia (Doe 1’s mother) was home that evening, as were Doe 1’s three siblings. Sonia was wearing a pajama shirt and pajama bottoms. At first, Hughes and Sonia were saying that they missed each other, and Hughes hugged Sonia.

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