People v. Sullivan CA2/3

CourtCalifornia Court of Appeal
DecidedDecember 16, 2025
DocketB336139
StatusUnpublished

This text of People v. Sullivan CA2/3 (People v. Sullivan CA2/3) 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. Sullivan CA2/3, (Cal. Ct. App. 2025).

Opinion

Filed 12/16/25 P. v. Sullivan CA2/3 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

SECOND APPELLATE DISTRICT

DIVISION THREE

THE PEOPLE, B336139

Plaintiff and Respondent, (Los Angeles County Super. Ct. No. NA117076) v.

VICTOR SULLIVAN,

Defendant and Appellant.

APPEAL from a judgment of the Superior Court of Los Angeles County, Daniel Lowenthal, Judge. Affirmed. Danalynn Pritz, under appointment by the Court of Appeal, for Defendant and Appellant. Rob Bonta, Attorney General, Lance E. Winters, Chief Assistant Attorney General, Susan Sullivan Pithey, Assistant Attorney General, Wyatt E. Bloomfield and Christopher G. Sanchez, Deputy Attorneys General, for Plaintiff and Respondent. ‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗

A jury convicted Victor Sullivan of second degree murder, attempted murder, evading a peace officer, and resisting an executive officer. The jury also found true a firearm enhancement as to two counts. On appeal, Sullivan contends the trial court’s exclusion of his mother, a potential witness, from the courtroom violated his constitutional right to a public trial. He also argues that the trial court abused its discretion in denying his motion to strike a firearm enhancement under Penal Code section 1385, subdivision (c)(2),1 and that his trial attorney’s failure to request a Franklin hearing violated his Sixth Amendment right to counsel. We affirm the judgment. FACTUAL AND PROCEDURAL BACKGROUND On May 7, 2021, Sullivan’s cousin Solana Villegas, Alexis Esteban, and Jose Monge drove to an apartment complex in San Pedro, where Villegas’s aunt lived. They parked and entered a stairwell, where they got into an argument with Sullivan. Sullivan shot Esteban in the head. The injury was fatal. Sullivan shot Monge twice, but he survived. After the shooting, Villegas went to her aunt’s apartment and told her that Sullivan had just shot Esteban. Villegas also told a detective that she saw Sullivan shoot Esteban. Surveillance videos showed a white Nissan at the apartment complex on May 7, 2021. The license plate on the white Nissan was registered to Sullivan. An eyewitness heard a

1 All further undesignated statutory references are to the Penal Code.

2 gunshot and then saw a white car exit the complex’s parking lot. Villegas later identified Sullivan as having been in a white car at the scene. The next day, a Los Angeles County Sheriff’s Department deputy sheriff was on patrol in Rancho Palos Verdes when she saw Sullivan in a white Nissan Sentra take off at a high speed and run a red light. The area was a mixed residential and business neighborhood, with busy streets. The deputy followed as Sullivan continued to speed and change lanes, without signaling, in heavy traffic. She turned on her marked car’s lights and siren to conduct a traffic stop. Sullivan failed to stop, sped up, ran another red light and stop signs, and continued to drive recklessly. Eventually, he parked in an alley and fled on foot. A Los Angeles County Sheriff’s deputy saw Sullivan run across the 110 freeway to an embankment. Sullivan resisted when the officer attempted to arrest him. They struggled and fell down the embankment. Eventually, the officer was able to detain and arrest Sullivan. Law enforcement recovered two firearms thrown from Sullivan’s vehicle during the pursuit. One was loaded. An expert testified at trial that one of the two recovered firearms was used to shoot Monge and Esteban. In August 2023, a jury convicted appellant of the second degree murder of Esteban (§ 187; count 1); attempted murder of Monge (§§ 664, 187; count 2); evading a peace officer (Veh. Code, § 2800.2; count 3); and resisting an executive officer (§ 69; count 4). The jury also found true two firearm enhancements (§ 12022.5, subd. (a)).

3 Sullivan admitted a prior strike (§ 667, subds. (b)–(j)), and two aggravating circumstances (Cal. Rules of Court, rule 4.421(a)(2), (b)(1)). The trial court sentenced Sullivan to 15 years to life, plus 10 years for the section 12022.5, subdivision (a) enhancement on count 1, 7 years on count 2, 8 months on count 3, and 8 months on count 4. DISCUSSION I. The Trial Court Did Not Violate Sullivan’s Right To a Public Trial Sullivan contends the trial court violated his constitutional right to a public trial by twice excluding his mother from the courtroom. The court excluded Sullivan’s mother at the beginning of the trial pursuant to Evidence Code section 777 because she was a potential witness. Although she was later allowed to return, the court apparently excluded her again during defense counsel’s closing argument, until the end of trial, due to her disruptiveness in the courtroom. Although Sullivan frames the alleged error as a violation of his constitutional right to a public trial, the trial court did not close the proceedings to any spectators. The trial court did not abuse its discretion by excluding and removing Sullivan’s mother from the courtroom, or violate Sullivan’s constitutional rights to an open trial. A. Background On August 9, 2023, the trial court granted the People’s motion in limine “to exclude potential witnesses” pursuant to Evidence Code section 777. Based on this motion, the prosecution moved to exclude Sullivan’s mother, Nellina Hill, from the audience. Defense counsel objected on the basis that Hill was not going to be called as a witness, explaining “she was

4 in a video, but she can’t speak to any of the relevant facts related to what [the prosecutor] has to prove.” The prosecutor responded that Hill was a percipient witness to evidence that would be presented through officer testimony. Thus, she was a potential witness. Defense counsel argued that it was unlikely the People would call Hill as a witness and “[j]ust because she’s in a video does not mean she should be excluded.” The prosecutor replied: “She’s not only in the video, she is there for a scene that will be presented to the jury, so I think she has to be excluded.” The court inquired about the contents of the video. The prosecutor explained that it was recorded two weeks before the murder and showed Sullivan being stopped and arrested in the same vehicle he was driving on the day of the murder, thus corroborating that he drove the vehicle the day of the murder. The prosecutor stated, “So it’s corroborating evidence that even though it’s not the murder charge, it’s very relevant to the People’s case and our evidence.” The court responded that “it does sound as though she’s a potential witness and she needs to be excluded. So I’m going to exclude her this morning. We can revisit it at lunchtime before 1:30[ ] [i]f you have any additional facts to support the belief that she will not or could not be called as a witness.” Defense counsel added that the video was the best evidence and that Hill would only offer cumulative evidence. The court stated, “I hear you, and I will reconsider at a later point in time. But for now, I want to maintain the status quo, and she will be excluded.” The court then excluded Hill as a “potential witness.” Defense counsel did not raise the issue of Hill’s exclusion after lunch, or during the next two days of trial, Thursday and Friday, August 10 and 11.

5 On the morning of Monday, August 14, the prosecutor told defense counsel it was “fine” with him if Hill wanted to return to the courtroom. The prosecution called two more witnesses before Sullivan asked the court, “I was wondering, because my mom got kicked out.” Defense counsel interjected, “I’m sorry, I meant to ask.

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Bluebook (online)
People v. Sullivan CA2/3, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-sullivan-ca23-calctapp-2025.