People v. White CA4/1
D082503
Cal. Ct. App.Mar 11, 2025Background
- Columbus White was convicted of human trafficking, pimping, and pandering involving four women, including one minor, in early 2022 in San Diego County.
- The prosecution introduced extensive text message exchanges between White and the alleged victims, and presented expert testimony explaining terminology and trafficking practices shown in those texts.
- The trial court admitted the texts as operative facts, instructing the jury not to consider them for their literal truth but to provide context for the alleged crimes.
- Expert Detective Dierdorff testified about the significance of the text messages and other circumstantial evidence, such as Cash App transactions, escort ads, and videos implicating White in pimping.
- The defense argued the texts were inadmissible hearsay and that the expert improperly relied on their truth in forming his opinion, especially referencing People v. Sanchez.
- White was convicted on all counts and sentenced to 24 years, then appealed on evidentiary grounds.
Issues
| Issue | White's Argument | People's Argument | Held |
|---|---|---|---|
| Admissibility of Texts as Evidence | Texts were inadmissible hearsay and relied on for their truth, violating Sanchez. | Texts admissible as operative facts and under hearsay exceptions, not for their literal truth. | Texts admissible as operative facts; not hearsay or were excepted. |
| Expert Reliance on Hearsay | Dierdorff improperly relied on texts' truth in forming his opinion. | Expert testimony was about typical pimp/prostitute relationships; reliance proper under exceptions. | No error; expert could rely on properly admitted hearsay. |
| Application of Coconspirator Exception for Minor (Maria) | Maria, as a minor and statutorily immune, could not be a coconspirator. | Immunity does not prevent treating minor as uncharged coconspirator for hearsay. | Exception applies; texts admissible. |
| Effectiveness of Limiting Instruction | Jury could not ignore the truth of texts despite instructions. | Instruction was sufficient; the texts’ truth not central to conviction. | Instruction sufficient; no basis for reversal. |
Key Cases Cited
- People v. Sanchez, 63 Cal.4th 665 (Cal. 2016) (Limits on expert testimony based on hearsay).
- People v. Smith, 179 Cal.App.4th 986 (Cal. Ct. App. 2009) (Texts as operative facts in criminal cases).
- People v. Dell, 232 Cal.App.3d 248 (Cal. Ct. App. 1991) (Admissibility of out-of-court statements as verbal acts in pimping cases).
- People v. Brown, 14 Cal.App.5th 320 (Cal. Ct. App. 2017) (Uncharged coconspirators, including immunized minors, for hearsay exceptions).