People v. Nelson CA3

CourtCalifornia Court of Appeal
DecidedDecember 3, 2024
DocketC099118
StatusUnpublished

This text of People v. Nelson CA3 (People v. Nelson 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. Nelson CA3, (Cal. Ct. App. 2024).

Opinion

Filed 12/3/24 P. v. Nelson CA3 NOT TO BE PUBLISHED California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published,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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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 (Placer) ----

THE PEOPLE, C099118

Plaintiff and Respondent, (Super. Ct. No. 62-183112B)

v.

PETER JAMES NELSON,

Defendant and Appellant.

Conspiring with two inmates, defendant Peter James Nelson fraudulently applied for unemployment benefits in the name of one of the inmates. A jury found him guilty of unemployment benefit fraud, conspiracy to commit unemployment benefit fraud, grand theft, and perjury by false application for aid. Defendant contends the trial court erred by not instructing the jury on the defenses of duress and necessity. He also asserts the court

1 sentenced him in violation of Penal Code section 654. (Statutory section citations that follow are found in the Penal Code unless otherwise stated.) Except to remand for resentencing, we affirm the judgment.

FACTS AND HISTORY OF THE PROCEEDINGS In 2020, Congress enacted the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act, 42 U.S.C. § 801(a)(2)(B)) to provide additional unemployment insurance benefits to persons affected by the COVID-19 pandemic. The law provided unemployment benefits to persons who were not otherwise eligible, such as those who were self-employed, worked as independent contractors, or worked part time, and who lost work due to the pandemic. The law also provided additional cash benefits and extended the maximum time a person could receive unemployment benefits from 26 weeks to 86 weeks. The Employment Development Department (Department), the state agency that processes claims for unemployment benefits, requires claimants to provide identification, income amounts, and employment status as part of their claim. The Department also requires benefit recipients, as a condition to receive the next benefit payment, to certify every two weeks that they remain unemployed but are able to begin work. Prior to the pandemic, the Department would verify a claimant’s income based on what was reported in the claimant’s W-2 form. The Department did this to establish the claim’s validity and the claimant’s benefit amount. The verification acted as a safeguard against fraud. After the CARES Act was adopted, however, the Department stopped verifying applicants’ incomes. This was due to the volume of claims and the urgency to make payments to individuals who had lost wages. Income verification would have delayed that process. Admittedly, after income verification was discontinued, the Department experienced an influx of fraudulent claims. It became aware that even inmates were

2 applying for unemployment benefits. Inmates are not eligible for unemployment benefits because they are not available to begin work. In the summer of 2020, Ronald Sandwell was an inmate in the Placer County jail. Defendant had previously been an inmate, but he was out of custody at the time. Using the jail’s phone system, Sandwell would contact defendant and provide him with other inmates’ information to use to apply for unemployment benefits. The two would agree to give a small amount of the money to the inmate and divide the remaining money between themselves. During a jail call on July 27, 2020, Sandwell introduced defendant to Travis Kevie, another Placer County jail inmate. In a subsequent call that day, defendant received Kevie’s personal information. Defendant applied for unemployment benefits in Kevie’s name the following day, July 28. On July 31, Sandwell and defendant discussed how they would divide Kevie’s unemployment payments. They planned to divide most of the money between themselves and give Kevie a small fraction. On August 3, 2020, defendant informed Sandwell that Kevie’s Department debit card had arrived. Defendant sent himself several payments from Kevie’s card, either directly from the card to his CashApp account, or indirectly from the card to Kevie’s CashApp account, which then forwarded the money to defendant’s CashApp account. Defendant also pulled cash directly off the card at ATM machines. In addition to filing the initial application for benefits on Kevie’s behalf, defendant filed under penalty of perjury 21 recertification applications for unemployment benefits on a bi-weekly basis for the remainder of 2020. In total, approximately $30,000 in unemployment benefits were fraudulently obtained on Kevie’s behalf. Defendant testified at his trial, and he admitted committing every crime charged against him. We will describe his testimony in more detail below. A jury found defendant guilty of unemployment benefit fraud, conspiracy to commit unemployment benefit fraud, grand theft, and perjury by false application for aid.

3 (Unemp. Ins. Code, § 2101, subd. (a); §§ 182, subd. (a)(1); 487, subd. (a), 118.) The trial court found true an allegation that defendant had previously been convicted of a serious or violent felony for purposes of the Three Strikes law. (§§ 667, subds. (b)-(i); 1170.12, subds. (a)-(d).) The trial court sentenced defendant to a prison term of seven years, four months: six years on the perjury conviction (the middle term of three years doubled for the prior strike), plus one year four months on the conspiracy conviction (one-third the middle term, doubled). The court sentenced defendant to concurrent terms of two years each, doubled to four years, for the fraud and theft convictions.

DISCUSSION

I

Necessity and Duress Instructions

A trial court must instruct a jury on any affirmative defense that is supported by substantial evidence in the record and is consistent with the defendant’s theory of the case. (People v. Salas (2006) 37 Cal.4th 967, 982.) Defendant contends the trial court erred by not instructing the jury on the defenses of necessity and duress. He asserts there was substantial evidence that his crimes were the product of necessity and duress, and the trial court thus had a duty to instruct on the defenses. We review de novo defendant’s claim that the court did not properly instruct on the applicable principles of law. (People v. Martin (2000) 78 Cal.App.4th 1107, 1111.)

A. Background

Any evidence of necessity or duress is to be found in defendant’s trial testimony, which we now summarize.

4 1. Defendant’s testimony

Defendant was arrested in 2017 and transferred to Sacramento County. Sandwell was defendant’s cellmate at the Sacramento County Jail. Defendant was “beyond scared” upon meeting him. Sandwell was an “extremely aggressive-looking muscular older gentleman” with multiple white power and tattoo icons over his chest. He was very aggressive and assertive. He asked to know defendant’s last name, race, and why he was there. He “called the shots” in that section of the jail, and defendant had to live by his rules. Sandwell told defendant he had spent time in Folsom Prison where he was an associate of the Aryan Brotherhood and was one of the gang’s “master weapon makers.” Defendant roomed with Sandwell for about a year and a half, and then he was moved to the Deuel Vocational Institute in Tracy. About two weeks after defendant arrived, a race riot broke out. Someone sucker-punched defendant in the face, smashing two of his front teeth and knocking him to the ground. He did not see who hit him. Defendant testified that about a month after arriving at Deuel, he received a note under his door.

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People v. Nelson CA3, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-nelson-ca3-calctapp-2024.