People v. Jackson CA5
F079700
| Cal. Ct. App. | Jun 30, 2021Background
- Jackson, a state prisoner, was charged with felony battery by a prisoner for allegedly spitting on Correctional Officer Ralph Hansen through holding-cell mesh.
- Incident: Hansen handcuffed Jackson for a medical escort; Jackson refused the appointment, was moved to a mesh holding cell, and allegedly spat at Hansen at ~1 foot distance, striking his face and chest.
- Two other officers observed or photographed spit on Hansen’s uniform and collected a paper towel used to dab the substance.
- DOJ criminalist tested the shirt and paper towel: inconclusive for saliva but positive for alpha‑amylase and nucleated epithelial cells, indicating an extremely high probability the substance was saliva.
- Jackson denied spitting and testified he would not risk parole; a jury convicted him of Penal Code §4501.5 battery and he admitted a prior strike; sentence affirmed on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence to support conviction for battery by a prisoner | People: Hansen’s eyewitness testimony, corroborating officer observations/photos, and forensic evidence showing alpha‑amylase and epithelial cells made a reasonable trier of fact could find Jackson guilty beyond a reasonable doubt | Jackson: Conviction rests on Hansen’s uncorroborated, unsupported assertion; forensic results were only a "mere possibility" and insufficient to prove he spat on Hansen | Affirmed. The combined eyewitness testimony, corroborating witnesses, photos, and forensic evidence were substantial; even Hansen’s credible eyewitness testimony alone would suffice unless impossible or inherently improbable |
Key Cases Cited
- People v. Cravens, 53 Cal.4th 500 (2012) (standard of review for sufficiency of evidence)
- People v. Medina, 46 Cal.4th 913 (2009) (presumption in favor of the judgment; reasonable inferences)
- People v. Duncan, 160 Cal.App.4th 1014 (2008) (uncorroborated testimony of a single credible witness can sustain a conviction)
- People v. Park, 112 Cal.App.4th 61 (2003) (circumstantial evidence can support conviction)
- People v. Flores, 176 Cal.App.4th 924 (2009) (elements of prisoner battery; bodily fluids as offensive touching)
- People v. Clark, 63 Cal.4th 522 (2016) (same standard applies to circumstantial-evidence cases)
- People v. Bellamy, 109 Cal. 610 (1986) (circumstantial evidence need not be mathematically certain)