People v. Paigly CA6

CourtCalifornia Court of Appeal
DecidedOctober 8, 2025
DocketH050724
StatusUnpublished

This text of People v. Paigly CA6 (People v. Paigly CA6) 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. Paigly CA6, (Cal. Ct. App. 2025).

Opinion

Filed 10/8/25 P. v. Paigly CA6 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

SIXTH APPELLATE DISTRICT

THE PEOPLE, H050724 (Santa Clara County Plaintiff and Respondent, Super. Ct. Nos. C21050909, C1919832)

v.

JEREMY PAIGLY,

Defendant and Appellant.

Defendant Jeremy Paigly was convicted by jury of attempting to dissuade a witness by threat of force, using force or threat of force against a witness, and misdemeanor sexual battery. Defendant contends the evidence supporting the two threat- based convictions is insufficient as a matter of law. He argues the convictions are invalid under Counterman v. Colorado (2023) 600 U.S. 66 (Counterman) because merely calling someone a “snitch” is protected speech under the First Amendment and because the jury was not required to find he subjectively intended to threaten the witness. He also asserts that his sexual battery conviction should be reversed because the jury was not instructed he could not form the required specific intent if he was asleep during the crime. For the reasons discussed here, we will affirm the judgment. I. BACKGROUND A. FACTUAL SUMMARY

Joe Paigly and his wife Doe (defendant’s brother and sister-in-law) were separated and living apart.1 After the separation, defendant had lived with Doe for a short time and they also had a sexual relationship of unspecified duration. One morning in early February 2021, Doe saw defendant sitting in his parked car outside her house. Defendant told her he was tired and that he had almost crashed his car. She invited him in to take a nap and offered to make him breakfast. Doe’s 19-year- old daughter (defendant’s niece) was asleep in the bed. When Doe left to cook breakfast, defendant had lain down in the bed but was not yet asleep. Defendant’s niece woke up when defendant touched her and began “grasping” her vagina over her clothes multiple times and also asked if he could “eat [her] pussy.” The young woman did not attempt to look at or speak to defendant because she was scared and confused by his actions. She texted her mother: “Tell him to leave already, he’s acting weird.” When Doe returned from the kitchen, her daughter was awake and defendant appeared to be sleeping. Doe woke defendant, handed him his breakfast and told him to go eat in another part of the house. Doe’s daughter did not tell her mother what happened, but she did tell her father Joe. Joe and Doe discussed the incident the next day. That same day, defendant called Doe to borrow a vacuum cleaner. Doe told defendant she and her daughter did not want to see him or want him in the house. Defendant insisted on getting the vacuum cleaner. Doe testified at trial that when he arrived, he looked “sad” and said to her “[t]his has to be a dream; this can’t be real.” According to Doe, Joe also discussed the incident with defendant’s ex-wife, who then informed defendant of that conversation.

1 We refer to Joe by his first name for clarity, without intending disrespect or familiarity. We refer to his wife as Doe in the interest of privacy. (Cal. Rules of Court, rule 8.90.)

2 Joe encouraged his daughter to report the incident to police, which she did a few weeks later. A detective interviewed her and Joe multiple times and also contacted defendant on March 22 regarding the investigation. At some point after the detective’s interviews, Doe informed Joe that defendant was “looking for” him. Then on April 23, defendant found and confronted Joe who was on a sidewalk waiting for a store to open. Defendant pulled up in his car, got out and called Joe a “snitch” while holding a knife. Defendant then began to chase Joe before returning to his car and driving away. Another man who was present heard someone say the word “snitch” but could not tell who said it. Joe ran away, afraid defendant might try to stab him. The other man also ran when he saw Joe start running and heard him say “run, run, take off.” Joe then called 911. He testified at trial that defendant was holding a knife, but on the day of the incident he had reported defendant was holding a gun. Joe explained that he thought defendant had a gun because he thought the other man said defendant had a gun and because Joe knew defendant often carried a gun. B. PROCEDURAL HISTORY

The Santa Clara County District Attorney charged defendant by information with dissuading or attempting to dissuade a witness by use of force or threat (Pen. Code, § 136.1, subd. (c)(1); count 1 [unspecified statutory references are to this code]); making a criminal threat (§ 422, subd. (a); count 2); misdemeanor sexual battery (§ 243.4, subd. (e)(1); count 3); and using force or threatening to use force or violence upon a witness (§ 140, subd. (a); count 4). The information further alleged that defendant used a dangerous or deadly weapon, a knife, in committing counts 1 and 4 (§ 12022, subd. (b)(1)). The information also alleged five prior strike convictions and that defendant was on bail at the time of the offenses (§ 12022.1, subd. (b)). As to the sexual battery charge, the defense argued that either defendant was asleep or only partially awake and mistakenly believed that he was touching Doe, with whom he had a sexual relationship. The defense did not seek an unconsciousness

3 instruction, but instead requested a mistake of fact instruction, which the trial court read to the jury. Regarding the witness threatening charges, the defense argued defendant merely called Joe a “snitch,” and challenged Joe’s testimony that defendant had chased him with a knife. The defense focused on Joe’s initial report that defendant had a gun rather than a knife, as well as differences between Joe’s account and the other witness’s recollection. Defendant contended Joe was lying about the weapon to retaliate for the sexual relationship between defendant and Doe. The jury found defendant guilty of dissuading or attempting to dissuade a witness (count 1), using force or threat of force against a witness (count 4), and misdemeanor sexual battery (count 3). The jury acquitted defendant of making a criminal threat (count 2). It also found not true the deadly or dangerous weapon allegations on counts 1 and 4. After a bifurcated court trial on the prior strikes and on-bail allegation, the trial court found those allegations true. The trial court ultimately struck all but one of defendant’s prior strikes, and sentenced defendant to a total term of four years in prison, consisting of four years (the lower term, doubled) on count 1 (§ 136.1, subd. (c)(1)); and a concurrent term of four years (the lower term, doubled) on count 4 (§ 140, subd. (a)), which the court stayed under section 654. The court struck the two years of punishment for the on-bail enhancement (§ 12022.1, subd. (b)) under section 1385, subdivision (b)(1). The court imposed a sentence of 364 days in county jail on the misdemeanor sexual battery charge (count 3), which was deemed served with presentence custody credits. II. DISCUSSION A. THE WITNESS THREATENING CONVICTIONS

Defendant contends the evidence supporting his witness threatening convictions is insufficient as a matter of law. In particular, he challenges Joe’s testimony that defendant was holding a knife when he called Joe a “snitch.” He argues that when considered

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People v. Paigly CA6, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-paigly-ca6-calctapp-2025.