People v. Martin CA2/6
B325048
| Cal. Ct. App. | Jun 17, 2024Background
- Travis Edward Martin was convicted by a jury of multiple child sexual abuse offenses, including seven counts of lewd acts on a child, posing a minor for sexual purposes, and possession of child pornography.
- Martin admitted to prior convictions for similar offenses and serious felony priors, boosting his sentence under the Three Strikes Law.
- The trial court sentenced Martin to a total of 610 years to life in prison.
- The case involved testimony from the current victim (Jane Doe), prior victims, and expert testimony on Child Sexual Abuse Accommodation Syndrome (CSAAS).
- Martin appealed, raising issues concerning evidentiary rulings, prosecutorial misconduct, the admissibility of expert testimony, the sentence's constitutionality, and the court's exercise of discretion regarding enhancements.
- The Court of Appeal affirmed the trial court's judgment and sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admission of prior sexual offenses (Evid. Code 1108) | Properly admitted to show propensity and pattern | Evidence was unduly prejudicial and dissimilar | Admission was proper; no abuse of discretion |
| Prosecutorial misconduct (closing argument) | No misconduct affecting outcome | Misstated evidence about prior offenses | Error was harmless and forfeited |
| Expert CSAAS testimony admissibility | Appropriate to explain victim behavior | Violated scientific reliability standards, improperly bolstered credibility | Properly admitted; not expert diagnosis/evidence of guilt |
| Sentencing enhancements and proportionality | Proper application of enhancements and law | Sentence is cruel, unusual, and excessive; enhancements should be stricken | Sentence not cruel/unusual; no abuse of discretion |
Key Cases Cited
- People v. Falsetta, 21 Cal.4th 903 (Cal. 1999) (discusses Evidence Code § 1108 and admissibility of prior sexual offenses)
- People v. Dillon, 34 Cal.3d 441 (Cal. 1983) (cruel and unusual punishment analysis under California constitution)
- Rummel v. Estelle, 445 U.S. 263 (1980) (upholds constitutionality of recidivist sentencing statutes)
- Ewing v. California, 538 U.S. 11 (2003) (affirms Three Strikes Law life sentence is constitutional)
- People v. Hill, 17 Cal.4th 800 (Cal. 1998) (prosecutorial misconduct—misstating evidence)
- People v. McAlpin, 53 Cal.3d 1289 (Cal. 1991) (CSAAS evidence used to address juror misconceptions about child victim behavior)