People v. Watson CA4/2, E083325

Alijah Jahmaal Watson was charged with two counts of forcible rape against two women (M.D. and D.M.A.), both of whom he met online.
In both incidents, Watson allegedly engaged in sexual conduct and ultimately forcibly raped the victims after they attempted to disengage.
During trial, Watson testified, disputing the claim that he would masturbate in public in front of a woman he did not know.
The prosecution introduced rebuttal evidence about a previous indecent exposure incident (the Rialto incident) to impeach Watson’s credibility.
Watson objected to the introduction of this evidence; the trial court limited the rebuttal to one incident and found the evidence admissible.
Watson was convicted and sentenced to 30 years to life; he appealed, arguing improper admission of impeachment evidence and clerical sentencing errors.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of prior indecent exposure for impeachment	Evidence relevant to challenge Watson’s credibility after his denial on the stand	Admission was improper, prejudicial, and unduly inflammatory	Admissible; trial court did not abuse its discretion
Clerical error in sentencing documents referencing Three Strikes Law	Concedes error present in documents	Argues for correction of sentencing records	Court ordered correction of error

People v. Ledesma, 39 Cal.4th 641 (Cal. 2006) (abuse of discretion standard for review of evidentiary rulings)
People v. Clark, 52 Cal.4th 856 (Cal. 2011) (trial court’s broad discretion in admitting impeachment evidence involving moral turpitude)
People v. Ballard, 13 Cal.App.4th 687 (Cal. Ct. App. 1993) (indecent exposure as conduct involving moral turpitude)
People v. Wheeler, 4 Cal.4th 284 (Cal. 1992) (relevance of evidence to witness's credibility under Evidence Code § 780)
People v. Gutierrez, 28 Cal.4th 1083 (Cal. 2002) (defendant who testifies is subject to impeachment)
People v. Karis, 46 Cal.3d 612 (Cal. 1988) (definition of prejudice under Evidence Code § 352)