People v. Fields CA3
C085659
| Cal. Ct. App. | Jun 30, 2021Background
- On April 18, 2016, defendant Bryant Eric Fields confronted J.W. at his ex-girlfriend B.D.’s apartment; as J.W. drove off in B.D.’s car, someone fired about 10 .40‑caliber rounds at the car and struck at least two other vehicles; no one was hit.
- Surveillance video showed an individual shooting at the vehicle; B.D. identified the shooter as possibly Fields based on clothing/appearance; J.W. did not testify.
- Police recovered a Glock .40 and .40‑caliber casings/ammunition from a Natomas residence; forensic testing tied the casings to that Glock; a backpack with paperwork bearing Fields’s name was also found there.
- A jury convicted Fields of attempted murder, multiple firearm and discharge counts, and felon-in-possession; numerous firearm‑use and prior‑conviction enhancements were found true; total sentence imposed was 51 years.
- On appeal Fields challenged evidentiary rulings (B.D.’s “manhunt” remark and her statement she returned “the next day”), asserted cumulative error, argued one firearm enhancement was improperly doubled, and sought remand/relief under Senate Bills 620, 1393, and 136.
Issues
| Issue | People’s Argument | Fields’s Argument | Held |
|---|---|---|---|
| Admission of B.D.’s testimony that she was worried Fields “was on some sort of manhunt” | Testimony was B.D.’s statement (not hearsay about Fields), and any error was harmless | Admission was hearsay/irrelevant and violated due process; if treated as defendant’s statement it was erroneous | Court assumed error but found it harmless beyond a reasonable doubt given overwhelming evidence tying Fields to the shooting |
| Testimony that B.D. did not return to her apartment “the next day” | Relevant to B.D.’s credibility and conduct after the shooting | Irrelevant and prejudicial; should have been excluded | Overruled on relevance; testimony was admissible and any due‑process claim fails; objection limited to relevance so other grounds forfeited |
| Cumulative‑error claim | N/A | The combined evidentiary errors denied a fair trial | Rejected — no prejudicial errors proven individually, so no cumulative prejudice |
| Doubling of the §12022.5 enhancement on count 4 (unauthorized sentence) | Conceded error | Challenged as an unauthorized sentence | Court agreed it was unauthorized; vacated that enhancement term and remanded for resentencing on that enhancement if not struck |
| Remand under SB 620 (court discretion to strike firearm enhancements) | SB 620 applies retroactively; remand unnecessary because record shows court would not have struck enhancements | Remand required so trial court can exercise discretion to strike/dismiss firearm enhancements | SB 620 applies retroactively; remand granted because record does not clearly show the court would have refused to strike the enhancements |
| Remand under SB 1393 (discretion to strike prior serious‑felony “nickel prior”) | SB 1393 applies retroactively; remand unnecessary | Remand required for trial court to decide whether to strike §667(a) enhancement | SB 1393 applies retroactively; remand ordered because the record doesn’t show the court would have declined to strike the prior |
| Strike under SB 136 (prior prison term §667.5(b)) | SB 136 applies retroactively; enhancement should be stricken | Same | Court agreed; struck the §667.5(b) one‑year prior prison term enhancement |
Key Cases Cited
- People v. Watson, 46 Cal.2d 818 (state harmless‑error standard for evidentiary rulings)
- Chapman v. California, 386 U.S. 18 (federal harmless‑beyond‑a‑reasonable‑doubt standard for constitutional error)
- People v. Geier, 41 Cal.4th 555 (application of Chapman inquiry to record showing whether error contributed to verdict)
- People v. Partida, 37 Cal.4th 428 (forfeiture by failure to make a timely and specific objection under Evid. Code §353)
- People v. McDaniels, 22 Cal.App.5th 420 (when remand is unnecessary under SB 620 if record clearly shows court would not have struck enhancement)
- People v. Jones, 32 Cal.App.5th 267 (similar SB 620 remand guidance)
- In re Estrada, 63 Cal.2d 740 (retroactivity presumption for ameliorative statutes)
- People v. Sok, 181 Cal.App.4th 88 (enhancements are added after base term and should not be doubled)
- People v. Barnwell, 41 Cal.4th 1038 (unauthorized sentence review may be raised on appeal)