People v. Pineda CA2/6
B267047
Cal. Ct. App.Jun 15, 2016Background
- In 2013 Pineda pled guilty to joyriding, obstructing an officer, and violating a gang injunction; he was released on PRCS in January 2014.
- In July 2015 Pineda was arrested on a PRCS warrant; Probation informed him there was probable cause and recommended 180 days in county jail.
- Pineda signed a written waiver of a revocation hearing and agreed to serve 180 days; he was arraigned with counsel and told the court Probation had explained his rights and the violations.
- A revocation petition alleged multiple PRCS violations including failure to obey laws, failure to report, drug use, and GPS noncompliance; a Williams motion to dismiss on due process grounds was denied.
- Pineda later admitted the violations and the superior court revoked PRCS and ordered 180 days in county jail (with credit).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Pineda was denied due process by lack of a Morrissey‑compliant probable cause hearing | County: PRCS procedures used were constitutionally and statutorily permissible; any defect did not prejudice outcome | Pineda: Probable cause "hearing" was an ex parte interview to obtain waiver; no PRCS form; hearing officer was not neutral | The court affirmed: procedures complied with precedent; no reversible due process violation because defendant admitted violations and suffered no prejudice |
| Whether the person conducting the probable cause determination was a neutral decisionmaker | County: Hearing officer (Meza) was not the supervising officer or the reporter and thus was neutral | Pineda: Meza acted as a nonneutral officer; a neutral hearing officer was required | Held neutral: Morrissey requires someone not directly involved; the hearing officer need not be a judge or lawyer and here was sufficiently neutral |
| Whether a defective probable cause process requires reversal when defendant admits violations and accepts sanction | County: Even if a Morrissey defect occurred, reversal is unnecessary absent prejudice | Pineda: Process defects undermined voluntariness and fairness of revocation | Held no reversal: defendant made no showing of prejudice; admission and served sanction leave nothing to remedy |
| Whether PRCS revocation procedures violate equal protection or due process generally | County: Procedures consistent with constitutional, statutory, and decisional law | Pineda: Procedures violate due process/equal protection | Held procedures upheld; court followed People v. Gutierrez and People v. Byron as controlling precedent |
Key Cases Cited
- Morrissey v. Brewer, 408 U.S. 471 (1972) (establishes due process protections for parole revocation proceedings)
- Spencer v. Kemna, 523 U.S. 1 (1998) (no remedy where respondent has fully served the challenged sanction)
- In re La Croix, 12 Cal.3d 146 (1974) (prejudice required to overturn a parole revocation for procedure defects)
- In re Winn, 13 Cal.3d 694 (1975) (burden on petitioner to show prejudice from revocation defects)
- In re Moore, 45 Cal.App.3d 285 (1975) (same principle on prejudice requirement)
- Williams v. Superior Court, 230 Cal.App.4th 636 (2014) (discusses probable cause determination and neutrality in PRCS context)
- People v. Gutierrez, 245 Cal.App.4th 393 (2016) (upholding PRCS revocation procedures)
- People v. Byron, 246 Cal.App.4th 1009 (2016) (same)