2 Cal. App. 5th 593
Cal. Ct. App.2016Background
- John Paul Raygoza was arrested in April 2011; bail initially set at $455,000. He could not post an extra $105,000 to avoid remand.
- The court reduced bail to $350,000 on the condition Raygoza enter Los Angeles County’s Electronic Monitoring Program (EMP) and serve home detention with an ankle monitor.
- The EMP contract required remaining inside the residence except for approved activities, admission of administrators for compliance checks, device monitoring, and allowed immediate retaking for violations.
- In September 2014 Raygoza pled no contest to false imprisonment and received a four-year sentence.
- He sought presentence custody credit under Penal Code § 2900.5 for days spent on electronically monitored home detention “pursuant to § 1203.018.” The trial court denied the credit because his home detention resulted from a court-ordered bail reduction rather than being placed in the program as inmates held “in lieu of bail.”
- The Court of Appeal reversed as to custody credit, holding that home detention meeting § 1203.018’s custodial conditions entitles a defendant to presentence credit regardless of whether placement resulted from a court order or administrative assignment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether days spent in electronically monitored home detention count as presentence custody under Penal Code § 2900.5 “pursuant to § 1203.018” | The People: Raygoza was not held "pursuant to § 1203.018" because he voluntarily accepted home detention as part of a bail-reduction agreement, not as an inmate held "in lieu of bail" under § 1203.018. | Raygoza: His home detention met § 1203.018’s custodial conditions and was effectively imposed because he could not afford the full bail; credit should be awarded. | The court held that § 2900.5 requires credit where the defendant’s home detention meets the custodial conditions of programs established pursuant to § 1203.018, regardless of whether placement resulted from a court-ordered bail reduction or administrative assignment. |
Key Cases Cited
- People v. Johnson, 183 Cal.App.4th 253 (2010) (§ 2900.5 applies to all defendants who have been in custody)
- People v. Mendez, 151 Cal.App.4th 861 (2007) (purpose of custody credit is to eliminate unequal treatment caused by inability to post bail)
- In re Rojas, 23 Cal.3d 152 (1979) (statutory reach of custody credit extends beyond jail custody)
- In re Joyner, 48 Cal.3d 487 (1989) (credit equalizes actual time served for same offenses)
- In re Young, 32 Cal.App.3d 68 (1973) (denial of presentence credit for indigent defendants raises equal protection concerns)
- People v. Mobley, 139 Cal.App.3d 320 (1983) (credit depends on custodial nature of placement, not procedure used to place defendant)
- People v. Lapaille, 15 Cal.App.4th 1159 (1993) (court awarded credit where home confinement was as custodial as programs authorized by statute)
- In re Kapperman, 11 Cal.3d 542 (1974) (statutory classification denying custody credit to some defendants violated equal protection)