People v. Meyers CA1/4

CourtCalifornia Court of Appeal
DecidedApril 30, 2025
DocketA169852
StatusUnpublished

This text of People v. Meyers CA1/4 (People v. Meyers CA1/4) 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. Meyers CA1/4, (Cal. Ct. App. 2025).

Opinion

Filed 4/30/25 P. v. Meyers CA1/4 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION FOUR

THE PEOPLE, Plaintiff and Respondent, A169852 v. KENNETH JOSEPH MEYERS, (San Mateo County Super. Ct. No. 23SF012674A) Defendant and Appellant.

Kenneth Meyers was charged with and convicted of felony grand theft for taking a home theater receiver from a Best Buy store in July 2023. Surveillance footage from the day before showed that Meyers placed the receiver in his shopping cart, took it to an area partially hidden from surveillance coverage, found a microwave there, removed items from the box for the microwave, and then attempted to check out with the microwave box. Initially unsuccessful in making the purchase, Meyers returned the next morning and completed it. Best Buy employees discovered the receiver was missing about a week afterwards. Later, a store manager discovered a microwave with no security sensors in the open box area. Meyers attempted to check out with a box for a fan on August 2, leading to his arrest. Meyers now challenges his conviction and sentence on four grounds. First, he argues that the jury should have been instructed pursuant to People v. Dewberry (1959) 51 Cal.2d 548 to help it resolve any reasonable doubt as between the charged grand theft and the lesser included offenses of attempted petty and grand theft. Next, he argues that the trial court should have instructed the jury that it could use the evidence of his uncharged conduct on August 2 and an incident in April 2016 for limited purposes only. Third, Meyers argues that the trial court relied on at least two improper factors at sentencing—its incorrect belief that Meyers rejected the Delancey Street residential substance abuse treatment program, and its lack of awareness that Meyers’s 2011 felony conviction had been reduced to a misdemeanor. Finally, Meyers points out that the trial court erroneously imposed an administrative fee. The Attorney General agrees that the administrative fee was invalid but disputes Meyers’s other claims of error, and maintains that the claimed errors would be harmless in any event. We remand to the trial court to correct the probation report and strike the administrative fee, and otherwise affirm the judgment. BACKGROUND I. Factual History A Best Buy manager, Michael Skinner, observed surveillance footage showing Meyers in the “open box” area of the store on July 20, 2023. “Open box” items are previous display items or items that have been returned and are being sold at a discount. Meyers was taking accessories and packing material for a $70 microwave in the open box area and putting them behind a different box. Best Buy had an Arcam home theater receiver in the open box area that day; the receiver’s normal retail value was $4,400, but it was discounted to $3,520.99. When the Arcam receiver was on display, it had no security tags attached. Surveillance footage showed the out-of-box Arcam receiver in

2 Meyers’s shopping cart on July 20, underneath a box for a different, $300 receiver. Another Best Buy manager, Scott Bolotaolo, was at the store on July 20. Later in the July 20 surveillance footage, near closing time, the boxes for the microwave and for the $300 receiver were in Meyers’s shopping cart, but the Arcam receiver was not there. Meyers attempted to purchase the microwave box, but was not able to due to a problem with the credit card he was using. He returned the microwave box to a shelf in the open box area and placed another box on top of it. On July 21, 2023, surveillance footage showed Meyers back at the Best Buy shortly after the store opened. He was in the open box area, with a shopping cart containing the box for the microwave. He succeeded in purchasing what appeared from the box to be a microwave. Skinner discovered the Arcam receiver was missing on July 29. On August 2, Meyers returned to the Best Buy. In surveillance footage, he was holding a box for a fan. Then, in the open box area, Meyers put the fan that had been in the box behind other boxes. Meyers moved to an area with projectors and had a projector in his hand. Meyers attempted to check out with the fan box, but Bolotaolo asked him to leave and confiscated the box. When Skinner returned on August 3, he watched the surveillance footage and saw that Meyers was the person he suspected was responsible for the theft on July 21. Skinner opened the fan box, which contained seven items, including the projector Meyers had been holding the day before. At least three of the items in the box typically would have security tags on them, but did not; no security tags were in the box. After searching the open box

3 area, Skinner found an open box microwave, along with detached security devices. II. Prior Offenses In September 2011, Meyers was convicted of felony commercial burglary. The probation report described the facts of the crime: Meyers “entered a Home Depot store and removed two flashlights, a screwdriver and a package of files, with a total value of $105.43, off the shelf. [He] walked around the store, concealed the items in his jacket and then walked past the open check stands (without paying) towards an exit.” When staff stopped him, Meyers resisted but was eventually arrested. In April 2016, Meyers was detained for shoplifting at the same Best Buy store. The store’s loss prevention officer found that Meyers had hidden two video cards in a box for a floor fan, purchased what appeared to be the fan in the box, and then was apprehended after Meyers set off the store’s security sensor. III. Procedural History For the July 2023 incident, Meyers was charged with felony grand theft, and with enhancements pursuant to Penal Code sections 1170.12, subdivision (c)(1) (one or more prior serious or violent felony); 1203, subdivision (e)(4) (multiple prior felonies); and 1170, subdivision (b)(2) (aggravating circumstances).1 He was tried by jury. After the close of evidence, the prosecutor argued to the jury that the facts of the August 2 incident were, as permitted by Evidence Code section 1101, subdivision (b), “offered for the limited purpose of absence of mistake, to show [Meyers’s] intent on the day[s] of the incident, July 21st and July 20th, and the method or manner in which [Meyers] carries out his

1 Undesignated statutory references are to the Penal Code.

4 thefts, his modus operandi, the manner or method of something being done by an individual.” Later, in discussing the elements of the crime, the prosecutor again referenced section 1101, subdivision (b), noting that Meyers’s conduct in April 2016 at the same Best Buy was relevant for the limited purpose of evaluating his intent. Before reviewing the surveillance footage of the August 2 incident, the prosecutor reminded the jury that “[Evidence Code] section 1101 [subdivision] (b) [is] being used to show the absence of mistake, the intent, and the modus operandi, particular way or method of doing something,” and that “the evidence that’s being admitted for that purpose is the August 2nd incident, which we’re now about to take a look at some of the relevant portions from” the surveillance footage.

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People v. Meyers CA1/4, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-meyers-ca14-calctapp-2025.