People v. Small CA3

CourtCalifornia Court of Appeal
DecidedOctober 27, 2025
DocketC101922
StatusUnpublished

This text of People v. Small CA3 (People v. Small 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. Small CA3, (Cal. Ct. App. 2025).

Opinion

Filed 10/27/25 P. v. Small CA3 NOT TO BE PUBLISHED California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published,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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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 (Tehama) ----

THE PEOPLE, C101922

Plaintiff and Respondent, (Super. Ct. No. 22CR-000578)

v.

GERALD EUGENE SMALL,

Defendant and Appellant.

Defendant Gerald Eugene Small pled guilty to felony failure to update his annual sex offender registration (Pen. Code, § 290.012, subd. (a))1 and was sentenced to three years’ formal probation. On appeal, Small challenges the trial court’s imposition of probation conditions regarding association with minors, completion of a sex offender treatment program, polygraph examinations, possession of pornography, electronic search, and electronic monitoring. We conclude the association with minors and

1 Undesignated statutory references are to the Penal Code.

1 pornography conditions are unconstitutionally vague or overbroad and will remand the case to the trial court to modify them. The judgment is otherwise affirmed. FACTUAL AND PROCEDURAL BACKGROUND In March 2024, Small was charged with failure to annually update his sex offender registration. (§ 290.012, subd. (a).) On June 10, 2024, Small pled guilty to the charge. The trial court suspended execution of a three-year state prison sentence, placed Small on three years’ formal probation, and ordered him to serve 330 days in county jail. A few weeks after he was sentenced, the probation department requested modification of Small’s probation to add conditions requiring sex offender registration (No. 28);2 prohibiting Small from associating with any person under 18 years of age (No. 29); requiring Small to complete a sex offender treatment program (No. 30); requiring Small to submit to polygraph examinations (No. 31); prohibiting Small from possessing pornographic material (No. 32); requiring Small to consent to warrantless searches of his electronic devices and provide passwords to his devices (No. 33); and placing Small on electronic monitoring for the duration of probation (No. 34). The probation department argued these additional conditions should be imposed given Small’s criminal history, repeated sex offenses, and sexually violent predator status. The department reported that Small had two previous sex offense convictions in Florida in 1994 and 2005.3 In 1994, Small was convicted of one count of lewd and lascivious acts with a child and three counts of engaging in sexual activities with a child in a familial relationship. In 2005, Small was convicted of lewd and lascivious acts with a child under 12. At a 2006 sentencing hearing in Florida, Small was found to be

2 Small does not challenge this condition, which is mandated by section 290. 3 Section 290.005 provides for sex offender registration in California of persons convicted of registrable offenses in out-of-state courts.

2 potentially eligible for involuntary civil commitment under Florida law as a sexually violent predator. The probation department also reported that Small had a Static-99R score of three, which falls into the average risk category with a five-year recidivism estimate of 6.5 percent. The trial court directed the parties to submit letter briefs addressing the probation department’s recommendation. In Small’s brief, he acknowledged he was designated as a sexual predator as a result of a plea, admission, and sentence in 2006. However, he was never subjected to involuntary civil commitment under Florida law and never found to meet the criteria of a sexually violent predator. Small argued the conditions the probation department recommended were not reasonably related to his current conviction for failing to update his sex offender registration in California. The People agreed that Small had not been found to be a sexually violent predator under Florida law. The People contended, however, the additional conditions were reasonably related to Small’s history of sexual offenses in Florida, which had required him to register under section 290. At a hearing on August 23, 2024, defense counsel argued that the additional probation conditions proposed were for those required to register as a sexually violent predator, which the People conceded Small was not. Counsel also pointed out that a defendant convicted of failing to register would not be required to submit to a polygraph examination or complete sex offender treatment, because these requirements were specific to new sex offenders.4 The People in response argued that all of the additional

4 Section 1203.067 provides that the terms of probation granted to a person convicted of certain sex offenses and required to register under section 290 include completion of a sex offender management program and “[w]aiver of any privilege against self-incrimination and participation in polygraph examinations, which shall be part of the sex offender management program.” (§ 1203.067, subd. (b)(3); see id., subd. (b)(2).)

3 probation conditions were reasonably related to Small’s multiple prior convictions in Florida. The trial court granted probation’s request, explaining that “just because the terms are used in different types of sexual cases routinely doesn’t mean they’re not appropriate for this case. That’s not the issue. The issue is whether or not a probationary term is helping the defendant in his rehabilitation. [¶] And so the question is is it reasonably related to rehabilitation. And the Court finds that all these terms are reasonably related in a failure to register pursuant to sex offense type case, which this is.” The trial court ordered Small’s probation conditions modified to include the conditions “exactly” as recommended by the probation department. Small appealed. DISCUSSION Small contends the challenged probation conditions Nos. 29, 30, 31, 32, 33, and 34 are invalid under California law and should be reversed because they are unrelated to his failure to register or rehabilitation. Alternatively, Small argues many of the conditions are unconstitutionally overbroad, vague, and violate his right to due process and should be modified. While we disagree that these conditions are invalid under California law, we agree that condition No. 29 prohibiting contact with minors and No. 32 prohibiting Small from possessing pornography are unconstitutionally vague and/or overbroad and will remand the case to the trial court to modify these conditions. A. Reasonableness “Penal Code section 1203.1 et seq. gives trial courts broad discretion to determine whether to grant an eligible defendant probation, and if so, what terms of probation will promote rehabilitation and protect public safety. [Citation.] A probation condition is valid under the statutory scheme if it relates to the crime for which the defendant was convicted, relates to other criminal conduct, or requires or forbids conduct that is reasonably related to future criminality.” (People v. Hall (2017) 2 Cal.5th 494, 498,

4 citing People v. Lent (1975) 15 Cal.3d 481, 486.) The Lent test is conjunctive—all three factors must be found in order to invalidate a probation condition. (People v. Balestra (1999) 76 Cal.App.4th 57, 65, fn. 3.) We apply the deferential abuse of discretion standard in reviewing probation conditions under the statutory scheme. (Id. at p. 65.) A trial court abuses its discretion only when the probation conditions imposed are arbitrary, capricious, or exceed the bounds of reason. (People v. Welch (1993) 5 Cal.4th 228, 233- 234.) Condition No.

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People v. Small CA3, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-small-ca3-calctapp-2025.