People v. Stills
35 Cal. Rptr. 2d 486, 29 Cal. App. 4th 1766, 29 Cal. App. 2d 1766 (1994)
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Rule of Law:
A defendant's admission of a prior conviction is invalid and constitutes reversible error if the trial court fails to advise the defendant of any of their constitutional rights (e.g., jury trial, confrontation, privilege against self-incrimination) and obtain an affirmative waiver, as such an admission cannot be deemed voluntary and intelligent under the totality of circumstances.
Facts:
- Frederick Douglas Stills resided at a boarding house in San Bruno with several other people, including Sharon Davis and her two children.
- On May 28, 1993, a dispute arose between Stills and one of Davis’s children regarding possession of a television remote control device.
- The dispute escalated when Sharon Davis entered the room, holding a kitchen knife she had been using for dinner preparation.
- Stills struck Davis with a vase and, shortly thereafter, with a lamp.
- Stills contended he acted in self-defense due to Davis’s threatening gestures with the knife.
- Davis and her daughter contended that Davis never raised the knife, dropped it after being hit by the vase, and was then hit on the head by Stills with the lamp.
Procedural Posture:
- An information charged Frederick Stills in the state trial court (Superior Court) with attempted murder, two counts of assault with a deadly weapon, and battery with serious bodily injury.
- The information further alleged that Stills had a prior serious felony conviction under Penal Code section 667, subdivision (a).
- A jury trial was held in the trial court.
- The jury found Stills guilty of assault with a deadly weapon (the lamp) and battery with serious bodily injury, finding he personally inflicted great bodily injury.
- The jury found Stills not guilty of attempted murder and assault with a deadly weapon (the vase).
- After the jury verdict, and out of the jury's presence, Stills admitted the prior serious felony conviction.
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Issue:
Does a trial court commit reversible error by accepting a defendant's admission of a prior conviction without providing any advisement of constitutional rights and obtaining an affirmative waiver thereof?
Opinions:
Majority - Haerle, J.
Yes, a trial court commits reversible error by accepting a defendant's admission of a prior conviction without providing any advisement of constitutional rights and obtaining an affirmative waiver thereof. The court affirmed that, under In re Yurko and People v. Howard, a defendant's admission of a prior conviction must be voluntary and intelligent, requiring the trial court to advise the defendant of their constitutional rights (right to a jury trial, right to confront witnesses, and privilege against self-incrimination) and obtain an express waiver of those rights. The Howard test emphasizes that the record must affirmatively show that the admission was voluntary and intelligent, focusing on the defendant's knowledge of their rights rather than merely whether the prior would have been found true. The court distinguished this case from People v. Guzman, where a partial advisement was deemed harmless error. Here, there were no admonitions or waivers whatsoever, meaning the record entirely lacked any indication that Stills knew of his constitutional rights or voluntarily waived them. Therefore, the admission was deemed invalid. The court also noted that Stills's admission on cross-examination did not prove an essential element for the enhancement (personal use of a weapon).
Analysis:
This case significantly clarifies the strict application of Yurko advisements in California, establishing that a complete failure to advise a defendant of their constitutional rights before accepting an admission of a prior conviction is not subject to a harmless error analysis. It reinforces the Howard test's focus on whether the record affirmatively shows a voluntary and intelligent waiver based on the defendant's knowledge of rights, rather than on the likelihood of the prior being true. This decision underscores the importance of protecting a defendant's fundamental constitutional rights in the context of admitting prior convictions, impacting sentencing enhancements and the procedural obligations of trial courts.
