People v. Hobbs CA1/2, A168137

William Hobbs was convicted in San Francisco of nine charges, including felony false imprisonment and two counts of sexual battery, arising from separate incidents involving 13 women between November 2021 and September 2022.
The crimes included aggressive unwanted physical contact, such as grabbing women in public places, with three charges specifically relevant to this appeal: felony false imprisonment and two sexual batteries.
Hobbs was sentenced to 30 months in county jail, followed by a consecutive three-year state prison term.
After trial, Hobbs moved for a new trial (or mistrial on count I), arguing that the verdict on felony false imprisonment was not unanimous based on a post-verdict juror declaration and challenging the sufficiency of evidence supporting several convictions.
The trial court denied the motion, finding the relevant portions of the juror's declaration inadmissible and concluding the verdict was in fact unanimous.
Hobbs appealed, challenging the trial court's refusal to order a new trial, as well as the sufficiency of the evidence supporting his felony and sexual battery convictions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Motion for New Trial Based on Jury Unanimity	No credible evidence of a lack of unanimity; juror declaration barred by Evidence Code section 1150	Declaration from Juror 3 shows vote was not unanimous on felony false imprisonment	Trial court did not err; declaration was inadmissible; verdict was unanimous
Substantial Evidence—Felony False Imprisonment	Evidence showed Hobbs used more force than necessary, amounting to felony conduct	Conduct amounted to, at most, misdemeanor false imprisonment	Sufficient evidence supported felony charge; conduct exceeded restraint needed
Substantial Evidence—Sexual Purpose in Sexual Battery	Circumstances and testimony showed intent for sexual arousal, gratification, or abuse	Acts were inappropriate but not done with sexual intent	Sufficient evidence for jury to infer sexual purpose from facts
Need for Evidentiary Hearing on Jury Misconduct	No strong possibility of misconduct warranting hearing	Juror's declaration required further investigation	No evidentiary hearing required; no material conflict in evidence

People v. Gonzales, 54 Cal.4th 1234 (juror misconduct review standard and Evidence Code section 1150 application)
People v. Whitmore, 80 Cal.App.5th 116 (definition of violence for felony false imprisonment)
People v. Castro, 138 Cal.App.4th 137 (force in felony false imprisonment can be shown by moving victim beyond simple restraint)
People v. Fernandez, 26 Cal.App.4th 710 (restraint element in false imprisonment)
People v. Martinez, 11 Cal.4th 434 (intent for sexual battery inferred from conduct and circumstances)