People v. Super.Ct. (Sanchez)
167 Cal. Rptr. 3d 115
Cal. Ct. App.2014Background
- People charged Sanchez with multiple offenses including conspiracy, burglary, shooting at an inhabited dwelling, attempted murder, and related enhancements.
- Sanchez and the District Attorney negotiated a plea: no contest to one count of attempted murder in exchange for a 25-to-life term and dismissal of other counts under a Harvey waiver.
- Plea form was signed; Sanchez was represented by three defense attorneys.
- At sentencing, the court noted 25-to-life was not authorized for attempted murder and imposed the legally authorized life with parole, creating a minimum term of seven years under law.
- The People sought to vacate the bargain; the trial court refused to enforce the 25-to-life term and effectively reformed the plea to a lesser punishment.
- Supreme Court directed the court to show cause; the appellate court ultimately granted relief to the People, vacating the plea and ordering reinstatement of counts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Mandate jurisdiction viability | People: mandamus proper; ordinary remedies inadequate. | Sanchez: writ not available if appeal adequate. | Writ jurisdiction proper; no adequate ordinary remedy. |
| Trial court authority to reform a negotiated plea | People: court cannot alter terms without consent to benefit defendant. | Sanchez: court could reform given mistake of law encountered. | Trial court exceeded jurisdiction by altering the bargain; reform improper. |
| Effect of mutual mistake of law on the plea | People: mistake of law allows rescission; court should vacate plea. | Sanchez: reform to reflect intended agreement. | Mutual mistake of law vitiates consent; rescission required; vacate plea. |
| Appropriate remedy and restoration | People: reinstate counts and enforce bargain; vacate plea. | Sanchez: court should adhere to what was plausibly agreed. | Vacate plea, reinstate counts, and remand for further proceedings. |
Key Cases Cited
- People v. Segura, 44 Cal.4th 921 (2008) (court cannot alter terms of negotiated plea without consent)
- Harris v. Rudin, Richman & Appel, 95 Cal.App.4th 1332 (2002) (mutual mistake of law can affect contract terms)
- People v. Velasquez, 69 Cal.App.4th 503 (1999) (prosecutor's duty to advise of permissible penalties; not controlling rule for mutual mistake)
- People v. Bean, 213 Cal.App.3d 639 (1989) (nullification of an illegal plea bargain required)
- People ex rel. Younger v. Count of El Dorado, 5 Cal.3d 487 (1971) (original mandamus jurisdiction when no adequate remedy at law)
- Castaneda v. Municipal Court, 25 Cal.App.3d 588 (1972) (exception to ordinary appellate remedy in extraordinary writs)
- People v. Martinez (Municipal Court case cited), 14 Cal.App.3d 362 (1971) (noting traditional right to appeal; applicability to writs)
- People v. Turner, 34 Cal.4th 406 (2004) (double jeopardy considerations and vacatur contexts)
- People v. Massie, 19 Cal.4th 550 (1998) (reaffirming limits on plea-bargain modifications)