People v. Hummel CA3

CourtCalifornia Court of Appeal
DecidedMarch 30, 2026
DocketC102903
StatusUnpublished

This text of People v. Hummel CA3 (People v. Hummel CA3) 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. Hummel CA3, (Cal. Ct. App. 2026).

Opinion

Filed 3/30/26 P. v. Hummel CA3 NOT TO BE PUBLISHED California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published,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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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 THIRD APPELLATE DISTRICT (Butte) ----

THE PEOPLE, C102903

Plaintiff and Respondent, (Super. Ct. No. 24CF04518)

v.

VANYA ERICSON HUMMEL,

Defendant and Appellant.

Defendant Vanya Ericson Hummel pleaded no contest to a charge of making criminal threats and the court sentenced him to an upper term of three years. Hummel does not contest his guilt but raises several challenges to his sentence. We affirm the judgment, but because we agree that Hummel did not validly waive his right to a jury trial on the aggravating sentencing factors and those factors were not properly proven, we vacate the sentence and remand the cause for a new sentencing hearing. PROCEDURAL BACKGROUND The underlying facts leading to Hummel’s conviction in this case are not relevant to the issues on appeal. It suffices to say that after Hummel had an encounter with

1 another person, he was arrested and charged with making criminal threats (Pen. Code, § 422, subd. (a); count 1)1 and vandalism (§ 594, subd. (a); count 2). The prosecution did not allege any aggravating factors in the information or complaint. The prosecution indicated it would be willing to dismiss the charge of vandalism in exchange for a guilty plea to making criminal threats.2 Hummel, representing himself, agreed to the offer. The court filled out a plea form and gave Hummel an opportunity to review and sign it before asking Hummel, “And does the fact that you initialed those boxes means that you agree with the content of the plea form? Do you agree with that?” Hummel replied, “Yes, Your Honor. I believe I may have accidentally initialed a couple boxes that I wasn’t supposed to initial. [¶] . . . [¶] . . . On page four or five.” The court responded, “It looks like you initialed all the ones you’re supposed to.” Of note, page No. 4 of the plea form covers consequences of the plea and page No. 5 specifically covers sentencing. Hummel initialed section No. 4 of the plea form, thereby stipulating that the court could take the factual basis for the plea “from the following documents, which will be summarized in the probation report.” Directly underneath, a box corresponding to “Probable cause declaration” was checked. Hummel also initialed section No. 4(a) that stated, “If I believe the summary in the probation report is incomplete or incorrect, I may submit additional portions from the above documents.” Hummel also initialed section No. 4(b) that states, “I understand that the court cannot impose a sentence exceeding the middle term unless there are circumstances in aggravation justifying a greater term. I understand that I have the right to a jury trial or

1 Undesignated statutory references are to the Penal Code. 2 Hummel was initially arraigned on the charges in this case, another unrelated case, and on a charge of violation of probation in case No. 24CM03914. In light of Hummel’s no contest plea in the instant case, the court found Hummel “in violation of his probation in the misdemeanor case ending in 3914.”

2 court trial where any facts underlying an aggravating circumstance must be proven beyond a reasonable doubt.” Lastly, Hummel initialed section No. 4(c) that states, “I give up this right and agree that the judge may find aggravating factors based on the documents described above, and the court may sentence me to the lower, middle, or upper term.” The court then discussed Hummel’s right to a jury trial “in this case,” explained his rights and stated, “If you plead no contest to this charge, that means that you’re giving up those rights, sir. Is that what you want to do today?” Hummel answered affirmatively. The court did not specifically mention Hummel’s right to a jury trial on aggravating factors and, as we have indicated, no aggravating factors had been pled in the applicable charging document. Hummel then entered a plea of no contest to the criminal threat charge in count 1, and the court granted the prosecution’s motion to dismiss the vandalism charge with a waiver pursuant to People v. Harvey (1979) 25 Cal.3d 754. A probation report subsequently prepared for sentencing purposes indicated that pursuant to section 1203, subdivision (e)(4), Hummel was eligible for probation only in an unusual case, he was on conditional release in another matter, and his performance was unsatisfactory. The report also listed circumstances in aggravation pursuant to California Rules of Court, rule 4.421: “(b)(2) The defendant’s prior convictions as an adult or sustained petitions in juvenile delinquency proceedings are numerous or of increasing seriousness. [¶] The defendant’s record consists of three felonies and twenty- two misdemeanors.” A printed summary of Hummel’s criminal history was attached to the report. The report further indicated that under California Rules of Court, rule 4.421(b)(4) and (b)(5), Hummel was on probation or supervision when the instant offense was committed and his prior performance on such was unsatisfactory. During the sentencing hearing, the prosecution presented no evidence. The court relied upon the probation report and found as follows. First, the court found Hummel “is statutorily eligible for probation only in the unusual case, pursuant to Penal Code

3 1203(e)[(4)]. I’ve looked at that unusual case criteria. I don’t find that this case meets any of that criteria. So probation is denied. [¶] Even if you weren’t presumptively ineligible for probation, probation would be denied based on the nature, seriousness and circumstances of this case. And his prior record of criminal conduct indicates a pattern of regular criminal conduct. [¶] The Defendant did stipulate to the possible existence of aggravating factors being found true by the Court, by virtue of his initialing items 4(b) and 4(c) on the change of plea form. [¶] In reviewing the appropriate Rules of Court, I do find on balance that the circumstances in aggravation outweigh the circumstances in mitigation. [¶] In aggravation, the Defendant has an extensive prior criminal history consisting of three prior felonies and 22 prior misdemeanors as reflected in the records included in the report that were certified by the Probation Department. He was on a grant of misdemeanor probation . . . when he picked up the new charge. [¶] So for those reasons, for the violation of Penal Code 422(a), as charged in Count 1, I designate that the principal term and sentence him to state prison for an upper term of three years.” Hummel filed a notice of appeal but did not secure a certificate of probable cause. DISCUSSION I Sentencing Factors Hummel challenges the trial court’s determination that he was ineligible for probation and its upper term sentence. We review procedural due process claims de novo because “ ‘the ultimate determination of procedural fairness amounts to a question of law.’ ” (In re Jonathan V. (2018) 19 Cal.App.5th 236, 241.) A. Probation Ineligibility Except in unusual cases in which the interests of justice would best be served by the grant of probation, section 1203, subdivision (e)(4), prohibits the trial court from granting probation to “[a]ny person who has been previously convicted twice in this state

4 of a felony.” At sentencing, the trial court agreed with the probation department that Hummel was presumptively ineligible for probation pursuant to section 1203, subdivision (e)(4).

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People v. Hummel CA3, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-hummel-ca3-calctapp-2026.