People v. Stylz
2 Cal. App. 5th 530
Cal. Ct. App.2016Background
- Adam Stylz forced entry into locked storage unit No. B309 leased by Paul Foley and took property Foley valued at $4,805.
- Charged with burglary (Pen. Code § 459) and grand theft; pled no contest to second degree burglary and grand theft was dismissed.
- Sentenced to three years formal probation.
- After Prop. 47, Stylz petitioned under Penal Code § 1170.18 to recall sentence, arguing his burglary should be reduced to misdemeanor shoplifting under § 459.5 (claimed property value under $950).
- Trial court denied the petition, concluding a locked storage unit is not a "commercial establishment" open for sale and thus does not meet § 459.5 shoplifting definition; Stylz appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether entry into a locked storage unit during facility hours can be "shoplifting" under § 459.5 | People: The storage facility is a commercial establishment; entry during business hours with intent to steal could qualify as shoplifting if value ≤ $950 | Stylz: He entered the facility during regular hours and took property worth under $950, so § 459.5 applies and his felony should be reduced | Court: Entry into a specific locked storage unit leased by a private renter is burglary, not shoplifting; § 459.5 does not apply |
| Whether a storage unit is a "commercial establishment" under § 459.5 | People: The facility is a commercial business, but the locked unit itself is not an establishment open for commerce | Stylz: The entire storage facility is commercial and open during business hours, so unit entry fits § 459.5 | Court: The individual locked unit is not primarily engaged in buying/selling and is secured/private; it is not a commercial establishment for § 459.5 |
| Whether entering a secured subunit creates a separate expectation of privacy sufficient for burglary (Garcia principle) | People: Yes — a locked unit leased to an individual is a separately possessed space akin to a room or unit | Stylz: N/A on this point because he framed his relief under § 459.5 | Court: Applying People v. Garcia, the locked unit is a separately possessed, secured space; burglary conviction proper |
| Whether property valuation issues required remand if unit could be shoplifting | People: Trial court reserved on valuation but concluded statutory definition not met | Stylz: Offered counsel declaration valuing items under $950 | Court: No need to resolve valuation because statutory shoplifting elements were not satisfied |
Key Cases Cited
- People v. Garcia, 62 Cal.4th 1116 (clarifies burglary can be of an entire structure or a separately possessed internal space)
- People v. Wende, 25 Cal.3d 436 (procedural posture on appointed counsel and appellate review)
- In re J.L., 242 Cal.App.4th 1108 (definition of "commercial establishment" for § 459.5)
- People v. Rivera, 233 Cal.App.4th 1085 (discussing Proposition 47 effects)
- People v. Contreras, 237 Cal.App.4th 868 (discussing resentencing relief under Prop. 47)