People v. Maultsby
134 Cal. Rptr. 3d 542
| Cal. | 2012Background
- Defendant was convicted by jury of petty theft and admitted a prior felony conviction; the prior is a strike under Three Strikes and multiple theft priors were admitted.
- He appealed only the admission of the prior conviction, not the petty theft conviction itself.
- Section 1237.5 generally requires a certificate of probable cause to appeal a plea-based conviction (guilty or nolo contendere).
- Court of Appeal followed Fulton (2009) and held section 1237.5 applied to challenges to an enhancement admission.
- California Supreme Court held that section 1237.5 does not apply to appeals involving admissions of sentencing enhancements when the substantive charge was tried not guilty; thus no certificate is required.
- Court reversed the Court of Appeal and disapproved Fulton to the extent inconsistent with this decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does §1237.5 apply to challenges to an admission of a sentencing enhancement when the substantive charge was not pleabased? | People argued enhancement admissions are like guilty pleas and require a certificate. | Maultsby contends §1237.5 does not cover such admissions; no plea to the substantive charge. | No; §1237.5 does not apply to admissions of enhancements where the substantive charge was not pleaded guilty. |
| Should Fulton be disapproved where it extended §1237.5 to nonplea admissions? | Fulton correctly extended §1237.5 to enhancement admissions. | N/A or not directly stated in this phrasing. | Fulton is disapproved to the extent inconsistent with this opinion. |
| What is the proper scope of review and policy rationale for §1237.5 in this context? | Section 1237.5 screens frivolous appeals in guilty/nolo contendere pleas. | Acceptance of admissions should similarly be screened to promote efficiency. | §1237.5 is inapplicable here; review proceeds under §1237; efficiency concerns do not justify extending §1237.5 to admissions. |
Key Cases Cited
- People v. Fulton, 179 Cal.App.4th 1230 (Cal. Ct. App. 2009) (held §1237.5 applies to enhancement admissions even without guilty plea (disapproved in part))
- Chavez v. Superior Court, 30 Cal.4th 643 (2003) (distinguished appeal rights after not guilty pleas vs. guilty admissions)
- People v. Mendez, 19 Cal.4th 1084 (1999) (section 1237.5 as a procedural mechanism; not expansive to all admissions)
- People v. Hoffard, 10 Cal.4th 1170 (1995) (limits and purpose of §1237.5; defines scope of review after certificate)
- People v. Perry, 162 Cal.App.3d 1147 (1984) (early view equating enhancements with pleas for §1237.5 purposes)
- People v. Lobaugh, 188 Cal.App.3d 780 (1987) (admissions of enhancements treated like guilty pleas; distinguished by later rulings)
- People v. Jackson, 37 Cal.3d 826 (1985) (addressed admissions related to enhancements; not directly §1237.5 scope before Hoffard)
- In re Chavez, 30 Cal.4th 643 (2003) (reaffirms §1237 scope following not guilty pleas)