People v. Martin
51 Cal. 4th 75
| Cal. | 2010Background
- This case addresses whether Harvey limits probation conditions based on facts of a dismissed charge when a plea bargain is involved.
- Defendant Louis Lambert Martin pled guilty to felony resisting an officer in exchange for dismissal of a misdemeanor domestic violence charge, with probation including 120 days in county jail.
- The plea agreement did not mention probation conditions tied to the dismissed domestic violence charge.
- At a later hearing the trial court stated it would impose DV-related probation conditions derived from the dismissed charge, unless defendant objected or the plea was withdrawn.
- Defense counsel objected; the court implied it would reject the plea if the conditional terms were not accepted, and defendant ultimately agreed to all probation terms.
- The issue on appeal was whether probation conditions based on a dismissed charge could be imposed without the defendant’s express consent to those conditions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does Harvey bar probation conditions based on a dismissed charge without consent or transactional relation? | Beagle view applies to probation; Harvey restricts adverse consequences from dismissed charges. | Harvey does not apply to probation; probation is rehabilitative and within court discretion. | Harvey applies; consent or transactional relation required, but here consent was given. |
| Can a trial court impose negotiated probation conditions despite the plea terms, based on general statutory authority? | Plea terms bound court; Harvey/Segura limit modification by court. | ||
| Statutory authority to impose reasonable probation conditions can override plea terms. | General authority does not override; negotiated terms stand absent consent to changes. |
Key Cases Cited
- People v. Harvey, 25 Cal.3d 754 (Cal. 1980) (adverse sentencing based on dismissed charge prohibited absent consent or transactional relation)
- People v. Beagle, 125 Cal.App.4th 415 (Cal. Ct. App. 2004) (probation conditions linked to dismissed charge may be adverse consequences)
- People v. Segura, 44 Cal.4th 921 (Cal. 2008) (plea terms cannot be altered by court via probation modification)
- People v. Olguin, 45 Cal.4th 375 (Cal. 2008) (rehabilitation goals of probation do not override plea terms)
- People v. Howard, 16 Cal.4th 1081 (Cal. 1997) (probation purposes and conditions relate to permissible goals)