People v. Smothers CA1/2

CourtCalifornia Court of Appeal
DecidedMay 20, 2026
DocketA173523
StatusUnpublished

This text of People v. Smothers CA1/2 (People v. Smothers CA1/2) 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. Smothers CA1/2, (Cal. Ct. App. 2026).

Opinion

Filed 5/20/26 P. v. Smothers CA1/2 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

FIRST APPELLATE DISTRICT

DIVISION TWO

THE PEOPLE, Plaintiff and Respondent, A173523 v. BILLIE RAY SMOTHERS, JR., (Humboldt County Super. Ct. No. CR2403514) Defendant and Appellant.

After defendant Billie Ray Smothers, Jr. was convicted of assault with a deadly weapon, the trial court placed him on probation with various conditions. On appeal, defendant challenges one of the conditions related to substance use treatment, arguing that it amounted to an unconstitutional delegation of judicial authority to the probation officer. The Attorney General concedes the point. The Attorney General also argues, and defendant does not contest, that the same probation condition must be modified to remove the requirement that defendant pay the cost of any treatment. We agree that the challenged condition is invalid, and therefore remand to the trial court to strike or modify the condition. We also direct the trial court to amend the probation order to correct a discrepancy regarding its finding on an enhancement allegation.

1 BACKGROUND The facts of the underlying offenses are not at issue in this appeal so we limit our summary to the relevant procedural history. On February 11, 2025, the Humboldt County District Attorney filed an information charging defendant with assault with a deadly weapon (Pen. Code,1 § 245, subd. (a)(1); count 1) and making criminal threats of violence (§ 422; count 2). The information alleged that defendant inflicted great bodily injury in the commission of count 1 (§ 12022.7, subd. (a)), and that he used a deadly weapon in the commission of count two (§ 12022, subd. (b)(1)). The information further alleged the following aggravating circumstances: that the crime involved great violence, great bodily harm, threat of great bodily harm, or other acts disclosing a high degree of cruelty, viciousness, or callousness; that defendant was armed with or used a weapon at the time of the crimes; that defendant had engaged in violent conduct that indicated a serious danger to society; and any other aggravating factors permitted by law. (§ 1170, subd. (b)(2).) On April 23, a jury found defendant guilty of count 1, but acquitted him of count 2. Defendant waived the right to a jury trial on the special allegation and aggravating factors, and a court trial was held. The trial court did not find true the allegation that defendant inflicted great bodily harm in committing count 1. The court, however, found true the following aggravating factors: that the crime involved a threat of great bodily harm, cruelty and callousness, and that defendant was armed with a weapon. On May 21, the court placed defendant on two years’ probation with certain conditions. Defendant appealed.

1 Undesignated statutory references that follow are to the Penal Code.

2 DISCUSSION Defendant challenges one of his probation conditions, condition 19, which states: “Defendant shall be screened to determine if a medical necessity for substance use disorder treatment is indicated. If treatment is indicated, defendant shall undergo a full assessment as directed by the probation officer. Defendant shall enter and successfully complete all phases of the recommended treatment program. Said assessment and program will be at their own expense.” Defendant contends this condition violates the separation of powers doctrine by delegating judicial authority to the probation officer. Preliminarily, defendant acknowledges he did not object to the probation condition below. But he argues his claim is cognizable because it is a facial constitutional challenge presenting a pure question of law that does not depend on the underlying factual record. The Attorney General agrees. As do we. (See People v. Smith (2022) 79 Cal.App.5th 897, 901 (Smith) [a “facial constitutional challenge may be considered for the first time on appeal because it does not depend on the underlying factual record”], citing In re Sheena K. (2007) 40 Cal.4th 875, 884–886.) We thus address defendant’s constitutional challenge on the merits, which we review de novo. (Smith, supra, 79 Cal.App.5th at p. 902.) “Under the separation of powers doctrine (Cal. Const., art. III, § 3), judicial powers may not be delegated to nonjudicial officers. [Citation.] While the probation officer may properly specify the details necessary to effectuate the court’s probation conditions, it is the court’s duty to determine the nature of the requirements imposed on the probationer.” (Smith, supra, 79 Cal.App.5th at p. 902.) Put slightly differently, the “general rule [is] that a court may dictate the basic policy of a condition of probation, leaving

3 specification of details to the probation officer. . . . ‘However, the court’s order cannot be entirely open-ended. It is for the court to determine the nature of the prohibition placed on a defendant as a condition of probation.’ ” (In Victor L. (2010) 182 Cal.App.4th 902, 919.) “By leaving key determinations to be decided ad hoc, a vague probation condition may . . . result in an impermissible delegation of authority to the probation officer.” (Smith, at p. 902.) In Smith, the defendant argued that the condition requiring that she “ ‘participate in any treatment/therapy/counseling program, including residential, as directed by the probation officer,’ ” was vague, overbroad, and an improper delegation of authority. (Smith, supra, 79 Cal.App.5th at p. 902.) Our colleagues in Division Five concluded that when interpreted in the context of other conditions of the defendant’s probation, the challenged condition required only “treatment for substance abuse.” (Id. at p. 903.) So interpreted, the condition was not unconstitutionally vague or overbroad. (Ibid.) But Smith concluded that, even as narrowly interpreted to require only substance abuse treatment, the condition violated the separation of powers doctrine because it delegated to the probation officer the discretion to decide whether the defendant must attend a residential program, as opposed to an outpatient program. (Ibid.) Smith explained that “[g]iven the significant liberty interests at stake [imposed by residential placement], a court—not a probation officer—must” decide what kinds of treatment are required. (Ibid.; compare with People v. Penoli (1996) 46 Cal.App.4th 298, 307–308 [upholding a condition requiring the defendant to enter a residential drug treatment program but authorizing probation to select which residential program].) Defendant argues that condition 19 is similar to the condition in Smith.

4 He maintains that the condition “gives probation the discretion to determine: 1) whether [he] must attend a drug treatment program at all; and 2) the type of program,” which could include a residential treatment program. Thus, defendant contends the condition does not “simply . . . leave[ ] the details or particulars of the treatment program to probation’s discretion.” As a result, he argues condition 19 constitutes an improper delegation of judicial authority to the probation officer. The Attorney General concedes the point. We accept the concession.

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Bluebook (online)
People v. Smothers CA1/2, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-smothers-ca12-calctapp-2026.