People v. Ricardo C.
220 Cal. App. 4th 688
| Cal. Ct. App. | 2013Background
- Minor admitted to attempted robbery and a criminal-threats count as part of a negotiated plea; in exchange, other counts were to be dismissed and the agreed disposition was placement in the Youthful Offender Program (YOP) at Indio Juvenile Hall.
- The juvenile court accepted the plea but ordered a dispositional report and warned the parties it might later withdraw approval after reviewing probation's recommendations.
- Probation recommended an out‑of‑home placement but advised against immediate placement at YOP, recommending Twin Pines Ranch instead.
- At disposition the court declared minor a ward and, relying on probation’s report, ordered placement at Twin Pines and expressly prohibited placement at YOP without further order, contrary to the parties’ bargain.
- The prosecutor sought to withdraw the plea and reinstate dismissed charges; the court refused. The People appealed, arguing the court unlawfully altered the agreed plea disposition rather than rejecting the plea.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether People may appeal the juvenile court’s refusal to enforce the placement term of a plea bargain | The People argued the court’s dispositional order was an unlawful order appealable under Welf. & Inst. Code § 800(b)(5) because the court failed to honor the negotiated placement to YOP | Minor argued the appeal is barred because § 800(c) prohibits People’s appeals from orders granting probation and the People must seek writ relief instead | The court held the appeal was cognizable: this is an appeal from an unlawful dispositional order, not a proscribed attack on the grant of probation under § 800(c) (Jeffrey H. reasoning applies) |
| Whether a juvenile court may accept a plea bargain but impose a materially different dispositional term | People argued the court exceeded its authority by accepting parts of the bargain while refusing the material placement term, so it should have rejected the plea and reinstated charges | Court/Minor relied on the court’s duty to impose an appropriate disposition and its discretion after reviewing the probation report | The court held that once the judge withdrew approval of the plea by refusing the material term, the proper course was to reject the plea, withdraw admissions, and reinstate dismissed allegations — the judge could not enforce only parts of the bargain |
| Proper remedy when a court withdraws approval of an agreed disposition after accepting admissions | People sought reinstatement of dismissed counts or enforcement of the bargain | Minor argued refusal to enforce does not make the order unlawfully appealable; remedy was writ rather than appeal | Held that the juvenile court’s refusal to honor the bargain was unlawful and required reversal: the court should have set aside the plea and reinstated petitions |
Key Cases Cited
- People v. Segura, 44 Cal.4th 921 (plea agreements are binding on court once accepted; court must reject, not violate, plea bargains)
- In re Jeffrey H., 196 Cal.App.4th 1052 (People may appeal certain juvenile court orders that are not, in substance, appeals of probation grants)
- People v. Panizzon, 13 Cal.4th 68 (both parties entitled to benefits of plea bargains)
- People v. Collins, 21 Cal.3d 208 (remedies available when a party is deprived of benefits bargained for in a plea)
- People v. Johnson, 10 Cal.3d 868 (court may withdraw approval of a negotiated plea when it becomes more fully informed, but must then reject the plea rather than enforce altered terms)