People v. Rivas CA4/2

CourtCalifornia Court of Appeal
DecidedJune 12, 2024
DocketE080687
StatusUnpublished

This text of People v. Rivas CA4/2 (People v. Rivas CA4/2) 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. Rivas CA4/2, (Cal. Ct. App. 2024).

Opinion

Filed 6/12/24 P. v. Rivas CA4/2 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

FOURTH APPELLATE DISTRICT

DIVISION TWO

THE PEOPLE,

Plaintiff and Respondent, E080687

v. (Super.Ct.No. FWV20002875)

JULIO CESAR RIVAS, OPINION

Defendant and Appellant.

APPEAL from the Superior Court of San Bernardino County. Corey G. Lee,

Judge. Affirmed.

Spolin & Dukes, Aaron Spolin, Caitlin Dukes, Jeremy M. Cutcher, and Erica

Esquivel for Defendant and Appellant.

Rob Bonta, Attorney General, Lance E. Winters, Chief Assistant Attorney

General, Charles C. Ragland, Assistant Attorney General, Paige B. Hazard and Steve

Oetting, Deputy Attorneys General, for Plaintiff and Respondent.

1 Defendant and appellant Julio Cesar Rivas was convicted of sexually abusing two

girls on multiple occasions and sentenced to 278 years to life. In this appeal, he argues

his due process rights were violated because the amended information was not

“sufficiently specific” about when the alleged abuse occurred, and his trial counsel was

ineffective for failing to file a motion to challenge the information on that ground. He

also argues the jury instructions did not adequately emphasize that each individual count

must be proven beyond a reasonable doubt. We decline to consider his ineffective

assistance claim on direct appeal, and we find no error in the jury instructions. We

therefore affirm the judgment.

FACTS

According to the prosecution, Rivas sexually abused sisters Jane Doe (born Jan.

2008) and Mary Doe (born November 2005) for years. In May 2015, Rivas and his

girlfriend, who is the girls’ aunt, moved into the house where the girls lived with their

mother and father. Rivas is not married to the girls’ aunt, but the family treated him as if

he were. He is also Mary Doe’s godfather. Before they lived together, the aunt and

Rivas lived separately from the girls’ family, but the aunt would often babysit Mary Doe.

The abuse came to light in September 2019, after Jane Doe told an older cousin about it.

After Rivas was arrested, forensic examination discovered on his phone several videos

depicting Jane Doe’s genitals; the videos had been deleted but were recovered from a

cache file.

2 The amended information charged Rivas with 11 counts of lewd acts on a child 1 under the age of 14 (Pen. Code , § 288, subd. (a), counts 1-11). Counts 1 through 8

alleged Jane Doe as the victim of offenses committed between May 1, 2015, and

September 2, 2019. Counts 9 to 11 alleged Mary Doe as the victim of offenses

committed between November 22, 2010 and November 21, 2013. Each of these 11

counts alleged the special circumstances of the victim being a child under the age of 14

and the offenses involving multiple victims under section 667.61, subdivisions (j)(2) and

(e). The information also included a twelfth count, for possession of child pornography

(§ 311.11, subd. (a)), committed between July 23, 2019, and August 8, 2019. For all

twelve counts, the information alleged six specific aggravating circumstances, as well as

a catch-all for “any other aggravating factors.” (See § 1170, subd. (b)(2).)

Jane and Mary Doe testified at trial, as did Rivas. The jury found Rivas guilty on

all 12 counts, and found true each of the alleged enhancements. The trial court found true

each of the six alleged aggravating factors. The court sentenced Rivas to 11 consecutive

terms of 25 years to life for counts 1 through 11, plus a consecutive three year term for

count 12.

DISCUSSION

A. Due Process

Rivas argues that the “long time frames” pleaded in the amended information

“deprived [him] of his constitutional right to due process.” The argument is framed as a

1 Undesignated statutory references are to the Penal Code.

3 claim of ineffective assistance of counsel, as his trial counsel did not demur to the

information. (See People v. Scott (1994) 9 Cal.4th 331, 354 [generally, “only those

claims properly raised and preserved by the parties are reviewable on appeal”]; People v.

Jeff (1988) 204 Cal.App.3d 309, 342 (Jeff) [“Failure of a defendant to demur bars any

assertion on appeal of vagueness in the information. (§ 1012.)”].) In Rivas’s view, his

counsel’s failure to demur to the information hampered his ability to defend against the

charges by making it impossible to present “an alibi defense” or “full particulars to refute

the offenses.” We decline to consider the merits of Rivas’s arguments in this appeal.

To establish ineffective assistance of counsel, “the defendant must first show

counsel’s performance was deficient, in that it fell below an objective standard of

reasonableness under prevailing professional norms. Second, the defendant must show

resulting prejudice, i.e., a reasonable probability that, but for counsel’s deficient

performance, the outcome of the proceeding would have been different.” (People v. Mai

(2013) 57 Cal.4th 986, 1009.) On direct appeal, a conviction will be reversed for

ineffective assistance “only if (1) the record affirmatively discloses counsel had no

rational tactical purpose for the challenged act or omission, (2) counsel was asked for a

reason and failed to provide one, or (3) there simply could be no satisfactory explanation.

All other claims of ineffective assistance are more appropriately resolved in a habeas

corpus proceeding.” (Ibid.)

The record does not establish why Rivas’s trial counsel did not demur to the

information. Generally, “[s]o long as the evidence presented at the preliminary hearing

4 supports the number of offenses charged against defendant and covers the timeframe(s)

charged in the information, a defendant has all the notice the Constitution requires.”

(Jeff, supra, 204 Cal.App.3d at p. 342.) Nevertheless, the defendant “may demur if he or

she believes the lack of greater specificity hampers the ability to defend against the

charges.” (Ibid.) It is possible that counsel had no tactical purpose in not demurring to

the information, for example, if counsel failed to consider the possibility of doing so, or if

counsel unreasonably believed that more specificity would not help despite evidence

indicating it would help.

But it is also possible counsel had sound reasons not to pursue the issue. For

example, counsel may have reasonably concluded that the long time frames alleged did

not hamper any potentially viable defense, or even could work in Rivas’s favor one way

or another. In closing arguments, the defense emphasized the long time period during

which the offenses were alleged to have occurred. Indeed, it was the first substantive

point counsel made in the defense’s closing argument, and counsel returned to the theme

several times. Counsel implied that it is difficult to be certain about “where a person

was” in such a long period, that there were few times witnesses saw Rivas alone with

Jane Doe given the long period, and that only one photo and video in the long period

made it more likely they were taken by Jane Doe in borrowing Rivas’s phone. Counsel

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Related

Estelle v. McGuire
502 U.S. 62 (Supreme Court, 1991)
The People v. Mai
305 P.3d 1175 (California Supreme Court, 2013)
People v. Jeff
204 Cal. App. 3d 309 (California Court of Appeal, 1988)
People v. Posey
82 P.3d 755 (California Supreme Court, 2004)
People v. Covarrubias
378 P.3d 615 (California Supreme Court, 2016)
People v. Scott
885 P.2d 1040 (California Supreme Court, 1994)

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People v. Rivas CA4/2, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-rivas-ca42-calctapp-2024.