People v. Reyes, 35 Cal. App. 5th 538

On Sept. 3, 2016 Richmond police stopped a car driven by Jose Navarro; Denys Reyes was front-seat passenger. Officers found an orange backpack on the passenger floorboard containing a Glock with an attached 50‑round drum magazine; at least 40 rounds were loaded.
Reyes was charged with receiving a large‑capacity magazine (Pen. Code § 32310) and being a felon in possession of a firearm (Pen. Code § 29800); jury convicted Reyes on both counts after retrial and sentenced him to prison.
Prosecutor introduced Snapchat metadata from Reyes’s phone showing a user posted a story reading “Glock 17 with a 50 attached” the evening before the stop and that the story was viewed on Reyes’s phone.
Defense sought to admit hearsay statements by Navarro (who later was convicted at a joint trial) that during a search he told officers the gun was his and he placed it on the passenger side; trial court excluded the confession under Evid. Code § 1230 as insufficiently reliable.
Prosecution introduced evidence of a prior March 2016 incident in Napa where Reyes was found with two handguns in his car (Reyes was convicted in that prior incident); trial court allowed this prior‑conduct evidence to prove knowledge.
Court of Appeal reversed Reyes’s convictions, finding erroneous exclusion of Navarro’s confession and erroneous admission of Reyes’s prior uncharged gun possession prejudicial; it upheld admission of the Snapchat evidence.

Issue	Reyes' Argument	People / AG Argument	Held
Admissibility of Snapchat story	Snapchat was minimally probative and required assumptions; should be excluded	Snapchat post describing “Glock 17 with a 50 attached” viewed on Reyes’s phone was probative of knowledge	Admissible — court found relevance to knowledge and no undue prejudice
Exclusion of Navarro’s out‑of‑court confession (Evid. Code § 1230)	Navarro told police the gun was his and he put it on passenger side; admission under § 1230 was proper and reliable	Confession was untrustworthy — Navarro may have been protecting Reyes or acting strategically	Exclusion was an abuse of discretion; confession was against penal interest and sufficiently reliable; error prejudicial — reversal required
Admission of Reyes’s prior Napa gun possession (uncharged conduct)	Prior incident only showed propensity to possess guns and was inadmissible under § 1101	Prior similar conduct was probative of knowledge and absence of mistake	Admission was an abuse of discretion — prior incident lacked sufficient nexus to the knowledge at issue and was prejudicial

People v. Carter, 36 Cal.4th 1114 (court reviews relevancy determinations for abuse of discretion)
People v. Eubanks, 53 Cal.4th 110 (probative vs. prejudicial balancing under Evid. Code § 352)
People v. Westerfield, 6 Cal.5th 632 (standards for declarations against penal interest; § 1230 reliability analysis)
People v. Grimes, 1 Cal.5th 698 (consideration of circumstances, motives, and relationships in § 1230 trustworthiness inquiry)
People v. Hendrix, 214 Cal.App.4th 216 (limits on admitting uncharged misconduct to prove knowledge/absence of mistake)