Brown v. County of Los Angeles
177 Cal. Rptr. 3d 268
Cal. Ct. App.2014Background
- In 1987 Keith A. Brown pleaded guilty to second-degree murder and was sentenced to 17 years to life.
- In 2012 Brown filed a civil suit against Los Angeles County seeking $30 million and a declaration that his guilty plea was void on the ground he was 16 when he pled and thus lacked capacity to contract.
- Brown invoked Civil Code §§ 38 and 1556, arguing pleas are contracts and minors (or persons "entirely without understanding") cannot be bound.
- The trial court sustained the County’s demurrer without leave to amend and later entered dismissal; Brown appealed.
- The Court of Appeal considered whether a civil action may be used to attack the validity of an outstanding criminal conviction and whether civil contract incapacity rules govern plea bargains.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Brown may use a civil suit to void his guilty plea and recover damages | Brown: plea is a contract and voidable because he was a minor and coerced, so Civil Code incapacity rules apply | County: civil actions cannot be used to collaterally attack a criminal conviction; plea validity is governed by criminal procedures and habeas/direct appeal remedies | Held: Civil suit is barred as a collateral attack on an outstanding criminal conviction; dismissal affirmed |
| Whether civil contract incapacity statutes control validity of guilty pleas | Brown: plea agreement is a contract and Civil Code §§ 38/1556 void pleas by minors | County: plea acceptance and voluntariness are governed by Penal Code and criminal due process, not general contract law | Held: Civil incapacity statutes do not supplant criminal-law standards for plea voluntariness; age is one factor but not dispositive |
Key Cases Cited
- Yount v. City of Sacramento, 43 Cal.4th 885 (explaining civil suits cannot recover for harms that would invalidate outstanding criminal convictions without prior reversal)
- Heck v. Humphrey, 512 U.S. 477 (federal rule barring civil damages claims that would imply invalidity of conviction)
- People v. Kim, 193 Cal.App.4th 1355 (Penal Code governs plea acceptance and voluntariness; contract principles not dispositive)
- People v. Mortera, 14 Cal.App.4th 861 (minor’s age is one factor in plea voluntariness; Civil Code disaffirmance provisions do not control guilty pleas)
- People v. Shelton, 37 Cal.4th 759 (characterizing plea agreements in context of criminal law principles)
- Ricki J. v. Superior Court, 128 Cal.App.4th 783 (treating juvenile admissions as analogous to guilty pleas for voluntariness review)
- In re Uriah R., 70 Cal.App.4th 1152 (juvenile waivers generally valid; age alone insufficient to invalidate waiver)
- In re Charles P., 134 Cal.App.3d 768 (minor’s age does not automatically prevent waiver of rights)
Disposition: Order sustaining demurrer without leave to amend affirmed; parties to bear their own costs on appeal.