People v. Watkins

45 Cal. App. 4th 485, 53 Cal. Rptr. 2d 13, 96 D.A.R. 5569, 96 Cal. Daily Op. Serv. 3422, 96 Daily Journal DAR 5569, 1996 Cal. App. LEXIS 434
CourtCalifornia Court of Appeal
DecidedMay 14, 1996
DocketC020795
StatusPublished
Cited by7 cases

This text of 45 Cal. App. 4th 485 (People v. Watkins) 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. Watkins, 45 Cal. App. 4th 485, 53 Cal. Rptr. 2d 13, 96 D.A.R. 5569, 96 Cal. Daily Op. Serv. 3422, 96 Daily Journal DAR 5569, 1996 Cal. App. LEXIS 434 (Cal. Ct. App. 1996).

Opinion

Opinion

SIMS, J.

After Marisela Perez, the estranged girlfriend of Augusto Robles, left their shared apartment, she believed that some of her property remained on the premises. Perez marshaled defendants, Calvin Reese and Shean Watkins, to help her recover the property. Unfortunately, defendants interpreted their mission as a license to commit burglary (count I [Pen. Code, § 459; all subsequent undesignated section references are to the Penal Code]) assault with a firearm (count II [§ 245, subd. (a)(2)]), and robbery (count III [§211]). Defendant Reese was accused of personally using a firearm while committing these acts (§ 12022.5, subd. (a)), and defendant Watkins was accused of being armed with a rifle while committing them (§ 12022, subd. (a)(1)). Defendant Reese was additionally accused of being a convicted felon in possession of a firearm (count IV [§ 12021]). Both allegedly had prior records which brought them within the scope of section 667, subdivisions (a) and (b)-(i). 1

A jury convicted defendants of the above mentioned crimes (except as to count II, on which Watkins alone was acquitted) and found the weapons enhancements true. The trial court found the allegations of prior convictions true. Sentenced to lengthy terms in state prison, defendants claim a host of errors going to both the convictions and the sentences. In the published portion of the opinion, we conclude the trial court erroneously admitted a videotape of the conditional examination of a witness, but the error is harmless. In the unpublished portion of the opinion, we consider and reject defendants’ other contentions of prejudicial error. We shall therefore affirm the judgments.

Factual and Procedural Background *

*488 Discussion

I

Prosecution witness Jeffrey Arrich was unavailable to testify at trial because he had to leave the state by the time of trial. When informed of this fact, the trial court ordered a conditional examination of Arrich on videotape pursuant to section 1335 et sequitur. 5 A written transcript of the examination was also prepared. Over defendants’ objection that only the reading of the written transcript of the testimony at trial was authorized by law, the court then admitted the videotape in evidence.

Renewing their unsuccessful argument below, defendants contend it was prejudicial error to admit the videotape in lieu of the written transcript of the testimony. We agree admission of the videotape was error but conclude the error is harmless.

In approaching the issue tendered by defendants, we are mindful that, “Whether this court believes videotaping is as reliable as, or more advantageous than, the traditional means of recording a deposition is not the issue. Rather, the question presented is whether the use of videotape for the recording and reporting of deposition testimony has been authorized, by the Legislature.” (Bailey v. Superior Court (1977) 19 Cal.3d 970, 977 [140 Cal.Rptr. 669, 568 P.2d 394], original italics [no statutory warrant for videotaping of civil deposition]; see also Edmiston v. Superior Court (1978) 22 Cal.3d 699, 704 [150 Cal.Rptr. 276, 586 P.2d 590] [no statutory warrant for videotaping medical examination in civil case].) The procedures for taking a deposition in a criminal case may not conflict with statutory procedures governing conditional examinations set out in the Penal Code. (People v. Municipal Court (Runyan) (1978) 20 Cal.3d 523, 528 [143 Cal.Rptr. 609, 574 P.2d 425, 2 A.L.R.4th 681].)

The procedures for the taking and use of a deposition of a witness in a criminal case are set out in sections 1335 through 1345, dealing with the conditional examination of a witness. In construing this statutory scheme “ ‘We begin with the fundamental rule that a court “should ascertain the intent of the Legislature so as to effectuate the purpose of the law.” [Citation.] In determining such intent “[t]he court turns first tp the words *489 themselves for the answer.” [Citation.] We are required to give effect to statutes “according to the usual, ordinary import of the language employed in framing them.” [Citations.] “If possible, significance should be given to every word, phrase, sentence and part of an act in pursuance of the legislative purpose.” [Citation.] “[A] construction making some words surplusage is to be avoided.” [Citation.]’ (Moyer v. Workmen’s Comp. Appeals Bd. (1973) 10 Cal.3d 222, 230 .. . .)” (Woosley v. State of California (1992) 3 Cal.4th 758, 775-776 [13 Cal.Rptr.2d 30, 838 P.2d 758].)

In arguing that the statutory scheme does not allow admission of a videotaped deposition, defendants cite section 1343, which provides, “The testimony given by the witness must be reduced to writing, and authenticated in the same manner as the testimony of a witness taken in support of an information.” (Italics added.) If the statute is given its ordinary meaning, it plainly requires that the testimony shall be reduced to writing, not videotaping.

The Attorney General disputes this view. The Attorney General acknowledges he has issued an opinion concluding a videotape of a conditional examination may not be used in lieu of a written transcript. (67 Ops.Cal.Atty.Gen. 178 (1984).) However, he now contends his prior opinion was in error. According to the Attorney General, the requirement of section 1343, that testimony must be reduced to writing, must be read together with Evidence Code section 250, which provides: “ ‘Writing’ means handwriting, typewriting, printing, photostating, photographing, and every other means of recording upon any tangible thing any form of communication or representation, including letters, words, pictures, sounds, or symbols, or combinations thereof.” Since this broad definition of a “writing” includes a videotape, the Attorney General argues that the requirement of section 1343, that testimony be reduced to writing, is satisfied by videotaping the testimony.

We cannot accept the Attorney General’s new argument. The Evidence Code applies in criminal proceedings “Except as otherwise provided by statute . . . .” (Evid. Code, § 300.) Here, a written transcript of a conditional examination is “otherwise provided by statute” for three reasons.

First, the Attorney General’s argument proves too much. If Evidence Code section 250 governs the recording of deposition testimony, then it authorizes “every . . . means of recording upon any tangible thing any form of communication . . . .” The statute would thus authorize widely disparate *490 modes of recording testimony, ranging from videotapes to audiotapes to computer applications.

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Bluebook (online)
45 Cal. App. 4th 485, 53 Cal. Rptr. 2d 13, 96 D.A.R. 5569, 96 Cal. Daily Op. Serv. 3422, 96 Daily Journal DAR 5569, 1996 Cal. App. LEXIS 434, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-watkins-calctapp-1996.