People v. Villa CA5

CourtCalifornia Court of Appeal
DecidedApril 30, 2026
DocketF089038
StatusUnpublished

This text of People v. Villa CA5 (People v. Villa CA5) 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. Villa CA5, (Cal. Ct. App. 2026).

Opinion

Filed 4/30/26 P. v. Villa CA5

NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

FIFTH APPELLATE DISTRICT

THE PEOPLE, F089038 Plaintiff and Respondent, (Super. Ct. No. CR-24-000974) v.

LUIS MARTINEZ VILLA, OPINION Defendant and Appellant.

APPEAL from a judgment of the Superior Court of Stanislaus County. Maria Elena Ramos Ratliff, Judge. Robert F. Kane, under appointment by the Court of Appeal, for Defendant and Appellant. Rob Bonta, Attorney General, Charles C. Ragland, Chief Assistant Attorney General, Kimberley A. Donohue, Assistant Attorney General, Amanda D. Cary and Joseph Penney, Deputy Attorneys General, for Plaintiff and Respondent. -ooOoo- Defendant Luis Martinez Villa was convicted of one count of grand theft and two counts of petty theft. On appeal, defendant argues the trial court (1) prejudicially erred by prohibiting defense counsel from showing the jury a slideshow of celebrities during closing argument, and (2) abused its discretion by refusing to dismiss his prior “strike” conviction within the meaning of the “Three Strikes” law (Pen. Code, §§ 667, subds. (b)– (i), 1170.12, subds. (a)–(d))1 under section 1385 and Romero.2 We affirm. PROCEDURAL SUMMARY On May 10, 2024, the District Attorney of Stanislaus County filed an information charging defendant with grand theft (§ 487, subd. (a); counts I & II) and petty theft (§ 484, subd. (a); count III). As to counts I and II, the information alleged defendant had suffered a prior strike conviction (§ 667, subd. (d)). The information further alleged the circumstances in aggravation that defendant’s prior convictions were numerous or of increasing seriousness (Cal. Rules of Court, rule 4.421(b)(2)) and defendant had served a prior prison term (id., rule 4.421(b)(3)). On October 14, 2024, a jury convicted defendant of one count of grand theft (count II) and two counts petty theft (counts I & III).3 In a bifurcated proceeding, the jury found true defendant’s prior strike conviction allegation. The trial court granted the prosecution’s motion to strike the circumstances in aggravation in the interest of justice. The trial court sentenced defendant to two years on count II, which was doubled to four years under the Three Strikes law. The court further sentenced defendant on counts I and III to 90 days each, to run concurrent with the sentence on count II.4

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

2 People v. Superior Court (Romero) (1996) 13 Cal.4th 497 (Romero).

3 Although count I was charged as grand theft (§ 487, subd. (a)), the jury found defendant guilty of the lesser included offense of petty theft (§ 484, subd. (a)). 4 The court then terminated defendant’s probation in Stanislaus County Superior Court case No. CR-23-000657 for violating the terms of probation and imposed the

2. Defendant filed a timely notice of appeal. FACTUAL SUMMARY Count I A person was captured on surveillance footage entering a sporting goods store in Turlock on November 19, 2023, taking at least five items of merchandise totaling $1,250, and running out of the store without purchasing the items. A loss prevention manager of the store reviewed the surveillance footage from multiple cameras from different areas of the store and identified the person as defendant. Although the person was wearing a mask covering his face, the surveillance footage captured defendant pulling down his mask for a moment. The manager noticed the person’s “distinct features,” including his forehead, nose, hairline, mouth, and eyebrows. Before trial, the manager identified defendant in a “six-pack” lineup. The manager testified in court she was “[a] hundred percent” confident that the person in the surveillance footage was defendant. Count III On December 6, 2023, at a clothing store in Turlock, an employee observed a person walk into the store and walk “straight to the back” of the store. The employee saw the person’s face when he entered the store. The person was wearing a jacket and shorts. The employee reviewed the store’s surveillance footage and saw this person grab one piece of merchandise before placing it into his jacket. After someone approached him, the person grabbed multiple items of merchandise and ran out of the store. Once out of the store, the person got into a red SUV (sport utility vehicle) and disappeared out of the surveillance camera’s view. Prior to testifying, the employee was given a six-pack lineup. The employee reviewed the surveillance footage “over and over” and, once he was “comfortable” with

previously suspended sentence of eight months, one-third the middle term, which was run consecutively to the sentence in the instant case.

3. making an identification, noted “possible” next to defendant’s picture. In court, the employee identified defendant as the person who took the merchandise. Count II Later that same day, December 6, 2023, an employee at a different store in Turlock discovered an empty “merchandise protection” wrap taken from a missing vacuum cleaner. The vacuum cost $749.99 to purchase. A loss prevention manager of the store determined the vacuum had been taken without being purchased after reviewing the store’s surveillance footage and transaction history. From the footage, the manager watched a person remove the merchandise protection and put the vacuum into a shopping cart. The manager observed this person was a “Hispanic male wearing a black jacket, khaki shorts, [and] white shoes with … a black stripe on the back.” The manager further observed the person had distinct facial features including his hairline and smile. The footage showed the person leave the store through the “fire exit” and get in a red SUV. On December 12, 2023, another vacuum went missing from the same store. This vacuum was the same model and price as the one taken on December 6, 2023. When the manager examined the surveillance footage, she watched a person remove the merchandise protection from the vacuum and walk out of the store without making any attempt to pay for the item. Although the person was wearing a mask, the manager noticed this person looked “very similar” to the person who took the same model of vacuum on December 6. Specifically, the manager observed this person’s hairline, build, and shoes were the same as the person captured on December 6. She also saw similarities in how the item’s merchandise protection was removed and how the person walked inside the store. The manager further noticed it was the same item as the one taken on December 6, which was “not usually common especially within the time frame.” Prior to trial, the manager identified defendant in a six-pack lineup. The manager identified defendant in court as the person who took the vacuums.

4. Law Enforcement Investigation Detective N. Urban of the Turlock Police Department investigated retail theft in the area. Urban was assigned to investigate the two vacuums taken on December 6 and December 12, 2023. Urban was provided with defendant’s name. After viewing the surveillance footage from two of the stores and comparing the footage with pictures of defendant, Urban determined defendant was the person in the surveillance footage at those stores. DISCUSSION I. Closing Argument Defendant contends the trial court abused its discretion by prohibiting defense counsel from showing his slideshow presentation of celebrities during closing argument. The People contend the trial court did not abuse its discretion by doing so, but even assuming error, the error was harmless.

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People v. Villa CA5, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-villa-ca5-calctapp-2026.