People v. Loya
1 Cal. App. 5th 932
| Cal. Ct. App. | 2016Background
- Appellant Armando T. Loya was charged in two Kern County matters; in the trial case (BF151668A) a jury convicted him of multiple vehicle- and arrest-related offenses and the court found prior strikes/prior prison terms; aggregate sentence was 10 years. Companion probation-revocation case (BF144483A) resulted in a concurrent 6-year prison term.
- On the day set for trial, a negotiated plea deal (a principal four‑year term resolving both cases) was discussed; Loya equivocated and repeatedly asked about pleading not guilty by reason of insanity (NGI).
- After Loya indicated willingness to accept the negotiated deal, the trial judge abruptly announced the court would not accept the plea and withdrew it; trial proceeded.
- Loya had prior competency proceedings, a history of mental-health hospitalizations, and multiple Marsden (counsel substitution) hearings; some Marsden motions were denied.
- At trial the prosecution presented evidence of high‑speed flight from police, evasive driving, an escape and concealment in a parked car, a recorded jail call admitting he fled because he had contraband in the car, and a methamphetamine-induced coma on arrest. Loya presented no evidence.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Loya) | Held |
|---|---|---|---|
| Whether denial of opportunity to plead NGI was prejudicial | Any error in denying an NGI plea was harmless because record showed intentional flight and statements admitting avoidance of capture; NGI tied to voluntary intoxication is unavailable | Court prevented Loya from entering NGI plea; his mental‑health history and behavior warranted permitting NGI or at least inquiry | Harmless error on NGI claim; even if error occurred, no prejudice — NGI would not likely have succeeded |
| Whether denial of two Marsden motions was an abuse of discretion and prejudicial | Court acted within discretion; even if error occurred it was harmless because evidence did not support NGI and Loya’s conduct showed culpable intent | Counsel refused to allow NGI plea and Marsden denial prejudiced right to counsel choice and ability to present NGI | Did not reach abuse determination; assuming error, denial was harmless beyond a reasonable doubt — no reversible prejudice |
| Whether the trial court abused discretion by rejecting the negotiated plea without explanation | The court reasonably withdrew the offer because defendant equivocated and raised collateral concerns (credits/prior strikes) | Court arbitrarily withdrew the plea after Loya accepted it and gave no legitimate reason — abuse of discretion | Court abused its discretion in withdrawing the plea without stated justification; reversal and remand required |
| Appropriate remedy for court’s withdrawal of plea | Court/People argue specific enforcement is not required; traditional remedies vary | Loya asks remand to permit acceptance of prior plea or vacatur and retry if plea not approved | Judgment reversed and sentences vacated; remand: within 30 days DA must either resubmit the prior plea to the trial court for approval (including companion probation case) or elect to retry; if plea is approved, enter judgment consistent with it; otherwise retry |
Key Cases Cited
- People v. Henning, 178 Cal.App.4th 388 (Cal. Ct. App. 2009) (NGI‑plea procedures and prejudice standard discussed)
- People v. Clark, 52 Cal.4th 856 (Cal. 2011) (defendant controls plea decision; counsel cannot block NGI plea)
- People v. Clemons, 160 Cal.App.4th 1243 (Cal. Ct. App. 2008) (facts supporting NGI plea can require court to allow plea despite counsel objections)
- People v. Kaanehe, 19 Cal.3d 1 (Cal. 1977) (remedies for breach of plea bargains; withdrawal or resentencing)
- In re Alvernaz, 2 Cal.4th 924 (Cal. 1992) (remedy when ineffective assistance causes rejection of plea: resubmit plea to court or retry within set period)
- People v. Segura, 44 Cal.4th 921 (Cal. 2008) (role of plea bargains in criminal justice and requirement of judicial approval)
- People v. Stringham, 206 Cal.App.3d 184 (Cal. Ct. App. 1988) (trial court discretion to withdraw approval of negotiated plea)
- People v. Cobb, 139 Cal.App.3d 578 (Cal. Ct. App. 1983) (trial court may set plea deadlines for calendar management)