People v. Bringazi CA6, H051912

Joshua Kenneth Bringazi was convicted by a jury of stalking, false imprisonment, and invasion of privacy against T.P., following a series of unwelcome interactions, including use of a GPS tracker and repeated attempts to contact her.
The central incident involved Bringazi refusing to allow T.P. to leave his RV, driving off with her inside, and later brandishing a baseball bat when confronted by T.P. and her friend A.C.
Bringazi continued to contact T.P. after she attempted to cut off communication, appearing at hotels where she was hiding and using electronic means to track her.
The prosecution introduced evidence of uncharged conduct from 2006, where Bringazi entered a young woman's home without permission, to show intent and pattern.
Bringazi appealed the conviction, primarily challenging the sufficiency of the stalking evidence and the admission of prior uncharged conduct.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of Stalking Evidence	Evidence showed pattern of credible threat	Insufficient evidence of a credible threat or intent	Sufficient evidence; conviction upheld
"Credible Threat" Requirement	Actions, incl. baseball bat, implied threat	No serious expression of intent to commit violence	Pattern of conduct constituted a credible threat
Intent to Place Victim in Fear	Established by repeated willful harassing	Only intent to contact/follow, no fear intended	Intent to place T.P. in fear reasonably found
Admissibility of Uncharged 2006 Conduct	Relevant to intent and pattern	Too remote and dissimilar; unduly prejudicial	Properly admitted; not unduly prejudicial

People v. Bolin, 18 Cal.4th 297 (standard for reviewing sufficiency of evidence on appeal)
People v. Ewoldt, 7 Cal.4th 380 (standard for admissibility of uncharged acts to prove intent)
People v. Carter, 36 Cal.4th 1114 (standards for similarity in admitting uncharged crimes for intent)
People v. Kipp, 18 Cal.4th 349 (degree of similarity needed for admission of prior acts to show intent)