People v. Button, D070341

Defendant Edward Button and victim B.D. were former fiancés and college students; an altercation occurred on campus after the engagement ended.
B.D. slapped Button once with an open hand; Button immediately punched her twice in the face, causing three facial fractures and a concussion; she required surgery.
Button told a responding officer he had punched B.D., admitted starting the confrontation by grabbing her, and said he should be arrested; he did not assert self-defense to the officer.
A jury convicted Button of corporal injury to a spouse/roommate (Pen. Code § 273.5) and assault likely to produce great bodily injury (§ 245(a)(4)); the jury also found true allegations that Button personally inflicted great bodily injury (§ 1192.7(c)(8)).
Parties stipulated at trial that Button personally inflicted great bodily injury; the court instructed the jury to treat the stipulation as conclusively proved.
Sentence: 240 days (220 days stayed) and three years formal probation; Button appealed claiming (1) insufficient evidence to disprove self-defense, and (2) the trial court erred by not giving Boykin–Tahl admonitions before accepting the stipulation to the serious-felony allegation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence that Button did not act in self-defense	Evidence (anger, instigation, admissions, force causing fractures and concussion) supports conviction beyond reasonable doubt	Punches were immediate response to slap; force may have been reasonable given size disparity	Affirmed — viewed in light most favorable to prosecution, evidence was sufficient to support implicit finding that Button did not act in lawful self-defense
Trial court's failure to give Boykin–Tahl admonitions before accepting stipulation that defendant personally inflicted great bodily injury	Stipulation did not produce any immediate penal consequence and merely prequalified the offense as a possible serious felony for future prosecutions	Stipulation effectively admitted allegation and exposed defendant to future enhanced punishment (three-strikes risk) so admonitions were required	Affirmed — Boykin–Tahl warnings unnecessary because stipulation did not have the "definite penal consequences" (no immediate increased penalty) required to trigger those protections

Jackson v. Virginia, 443 U.S. 307 (establishes standard for sufficiency of the evidence review)
Boykin v. Alabama, 395 U.S. 238 (requires admonitions to ensure guilty pleas are knowing and voluntary)
In re Tahl, 1 Cal.3d 122 (California companion to Boykin on plea admonitions)
People v. Cross, 61 Cal.4th 164 (explains when stipulations/admissions trigger Boykin–Tahl based on "definite penal consequences")
In re Yurko, 10 Cal.3d 857 (requires admonitions for admissions of prior convictions that increase punishment)
People v. Ramirez, 50 Cal.3d 1158 (holds Yurko does not apply where admission does not inevitably increase penalty)
People v. Adams, 6 Cal.4th 570 (distinguishes stipulations of evidentiary facts from admissions that trigger Boykin–Tahl)
People v. Hernandez, 51 Cal.4th 733 (defines lawful self-defense elements in California)