People v. Yanez CA5

CourtCalifornia Court of Appeal
DecidedMay 15, 2026
DocketF089088
StatusUnpublished

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

Opinion

Filed 5/15/26 P. v. Yanez 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NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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, F089088 Plaintiff and Respondent, (Super. Ct. No. BF193772A) v.

STEVEN ANDREW YANEZ, OPINION Defendant and Appellant.

APPEAL from a judgment of the Superior Court of Kern County. David R. Zulfa, Judge. Ashwini Mate, 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 Caitlin Franzen, Deputy Attorneys General, for Plaintiff and Respondent. -ooOoo- INTRODUCTION In 2021, appellant Steven Andrew Yanez got into a dispute and physical altercation with two clerks inside a Bakersfield market that also resulted in Yanez causing more than $400 worth of damage to the store. In 2024, a jury convicted Yanez of felony vandalism (Pen. Code,1 § 594, subds. (a)(2) & (b)(1)) and two counts of misdemeanor assault. (§ 240). In doing so, the jury acquitted Yanez of two counts of assault with a deadly weapon against the two clerks (Counts 1 and 2; § 245, subd. (a)(1)),2 as well as a separate single count of assault with force likely to cause great bodily injury against one of them (Count 3; § 245, subd. (a)(4)). Instead, the jury returned two simple assault verdicts as lesser included offenses of Counts 1 and 3. The first conviction was based on the “stick” assault on the first clerk alleged in Count 1. The second involved the force likely count charged in Count 3, and was based on Yanez punching the first clerk in the face during the brouhaha. Yanez was entirely acquitted of assaulting the second clerk. The trial court imposed an upper–term three–year sentence on the felony vandalism conviction, and doubled it to six years based on a strike prior the jury also found true. (See § 667, subd. (e).) For the two misdemeanors, the court imposed a concurrent statutory maximum of six months on the first conviction (§ 241, subd. (a)), and another six months on the second misdemeanor which was stayed under section 654. Yanez raises two claims on appeal: (1) The misdemeanor assault convictions must be reversed because the statute of limitations for the two 2021 offenses had lapsed prior to the 2024 convictions; and (2) The sentence on the felony vandalism conviction was unlawful because it was based in part on four aggravating sentencing factors that Yanez had neither admitted nor waived his right to a jury trial.

1 All undesignated statutory references are to the Penal Code.

2 The prosecution’s alleged deadly weapon was a “wooden stick,” an approximately three foot long, one inch by one inch piece of wood. (See Defense Exhibit F.)

2. The People respond that Yanez’s statute of limitations claim was forfeited by his acquiescence in the trial court’s jury instruction on misdemeanor assault as a lesser included offense of the felony assault counts. They concede that the sentence on the vandalism conviction must be reversed and remanded because Yanez was entitled to a jury’s determination of those four factors and the trial court’s failure to obtain a jury waiver or admissions from Yanez was prejudicial error. We reject Yanez’s first contention but agree with the parties as to the second. DISCUSSION Because our review does not depend on the details of the offenses themselves, we need not relate them beyond what was described above. The first issue before us involves whether Yanez may for the first time on appeal contest the validity of his two 2024 misdemeanor assault convictions that were based on two 2021 offenses when the statute of limitations for misdemeanor assault is one year. The second issue focuses on how the trial court arrived at the sentence it imposed on the felony vandalism conviction. I. The 2024 Misdemeanor Convictions for 2021 Offenses. A. Background. On March 22, 2023, Yanez was arraigned on a complaint filed on March 3, 2023, almost two years after the charged offenses were alleged to have been committed on April 7, 2021; the record does not explain the delay in filing. In addition to a felony vandalism count, the complaint charged Yanez with two felony assault counts under section 245, subdivision (a)(1) and one count under section 245, subdivision (a)(4).3 Prosecution for both types of felony assault charged here must “be commenced within three years after commission of the offense.” (§ 801.) The prosecution’s original

3 An additional felony was also charged. When police responded to the scene and took Yanez into custody, he was uncooperative. However, the jury acquitted him of feloniously resisting a law enforcement officer (§ 69) and two lesser included misdemeanor offenses (§§ 148, subd (a)(1) & 240).

3. three aggravated assault charges were thus timely “commenced” when Yanez was arraigned on them in March 2023. (§ 804, subd. (c).) On the other hand, prosecution for misdemeanor assault must “be commenced within one year after commission of the offense.” (§ 802, subd. (a).) A jury “may find the defendant guilty of any offense, the commission of which is necessarily included in that with which he is charged[.]” (§ 1159.) Misdemeanor assault is necessarily included in felony assault. (See, e.g., People v. Alderson (1930) 105 Cal.App. 202, 202–203.) “The limitation of time applicable to an offense that is necessarily included within a greater offense is the limitation of time applicable to the lesser included offense, regardless of the limitation of time applicable to the greater offense.” (§ 805, subd. (b), italics added.) As discussed, the jury acquitted Yanez on all three felony assault counts and instead returned guilty verdicts on two misdemeanor assaults as lesser included offenses. However, a prosecution for a 2021 misdemeanor assault had not timely “commenced” — either when the original complaint was filed in 2023 or when the jury’s verdicts were reached in 2024 — because the statute of limitations had expired. The parties do not dispute whether simple assault is a necessarily included offense of aggravated assault, either under section 245, subdivision (a)(1) or (a)(4). Nor do they disagree that the statute of limitations for simple assault had run before the felony complaint in this matter was filed in 2023.4 They also agree that this statute of limitations dilemma was not raised or discussed in the trial court.

4 Although statutes of limitations may be tolled while a prosecution against the same person for the same criminal conduct is pending or ongoing (see § 803, subd. (b)), it is inapplicable here because the prosecution for this 2021 matter was not “commenced” until 2023, long after the misdemeanor one–year limitation period had already passed, i.e., it was neither pending nor ongoing.

4. In People v. Williams (1999) 21 Cal.4th 335 (Williams), our Supreme Court considered the question whether a defendant could raise a statute of limitations claim for the first time on appeal. (Id. at p. 339.) In its answer, the court focused on the charging documents, and concluded: “[W]hen the charging document indicates on its face that the action is time–barred, a person convicted of a charged offense may raise the statute of limitations at any time.” (Id. at p.

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Bluebook (online)
People v. Yanez CA5, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-yanez-ca5-calctapp-2026.