People v. Pelton CA5, F088056

Sean Michael Pelton was convicted by a jury in 2024 of grand theft and attempted grand theft of catalytic converters belonging to AT&T, stemming from incidents in December 2020 and January 2021 at an AT&T yard in Clovis, CA.
Pelton was already serving time for similar theft-related convictions from a separate county; his sentences were consolidated into a 14-year aggregate term.
At trial, evidence included surveillance footage, recovery of tools (Sawzall), and incriminating text/photos from Pelton’s cellphone linking him to the crimes.
The prosecution was permitted to introduce evidence of two prior convictions for similar thefts of catalytic converters from AT&T yards, over Pelton’s objection.
Pelton represented himself at trial and raised a single issue on appeal: that the admission of his two prior convictions was prejudicial and an abuse of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admission of prior convictions	Prior convictions show modus operandi, prove identity, plan, and intent; highly probative	Prior acts were too inflammatory and prejudicial, suggesting propensity; should be excluded under Evid. Code § 352	Admission was not an abuse of discretion; any error was harmless

People v. Davis, 46 Cal.4th 539 (Cal. 2009) (standards for admitting prior offenses to show intent, plan, identity)
People v. Ewoldt, 7 Cal.4th 380 (Cal. 1994) (similarity standards for prior acts when proving plan or intent)
People v. Williams, 17 Cal.4th 148 (Cal. 1998) (abuse of discretion standard in evidence rulings)
People v. Watson, 46 Cal.2d 818 (Cal. 1956) (standard for harmless error review)
People v. Rodrigues, 8 Cal.4th 1060 (Cal. 1994) (parameters of appellate review for evidentiary rulings)