The People v. Reginald Eugene Williams

Supreme Court of California
17 Cal.4th 148 (1998)

ELI5:

Rule of Law:

A trial court's discretion to dismiss a prior "strike" conviction in furtherance of justice under Penal Code § 1385(a) is limited. The court must consider whether the defendant falls outside the spirit of the Three Strikes law based on the nature of their current and past offenses, as well as their background, character, and prospects, and must state its reasons in the minutes.

Facts:

On February 9, 1995, Reginald Eugene Williams was stopped by a police officer while driving a vehicle on the streets of Los Angeles.
The officer determined that Williams, who was 32 years old, was under the influence of phencyclidine (PCP).
Williams had a lengthy adult criminal history dating back to 1981.
His record included 1982 felony convictions for attempted robbery and rape, which qualified as 'strikes' under California's Three Strikes law.
Between his 1982 'strike' convictions and his 1995 arrest, Williams was frequently incarcerated and amassed numerous convictions, including for firearm possession, multiple DUIs, and spousal battery just three months prior to the current offense.
Williams had a substance abuse problem since he was nine years old and was unemployed at the time of his arrest.
He had cohabited with a woman for several years, with whom he had two children, one of whom was disabled.

Procedural Posture:

The district attorney filed an information against Reginald Williams in the Superior Court of Los Angeles County, charging him with felony driving under the influence and alleging two prior 'strikes.'
After the trial court indicated it might be willing to strike one of the priors, Williams withdrew his not guilty plea and entered an 'open' guilty plea.
The superior court vacated one of the 'strike' findings (for attempted robbery) but failed to state its reasons in a written minute order.
The court sentenced Williams to nine years in prison, treating the case as a 'two-strike' matter.
The People, as appellant, appealed the sentence to the California Court of Appeal, Second Appellate District, arguing it was unlawful.
The Court of Appeal, appellee, reversed, finding the trial court abused its discretion and remanded with instructions to impose a 28-years-to-life sentence.
The California Supreme Court granted Williams's petition for review.

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Issue:

Does a trial court abuse its discretion under Penal Code § 1385(a) by dismissing a prior 'strike' conviction for a defendant with a continuous and recent criminal history, based primarily on the age of the prior strike and a mistaken belief about the defendant's intervening non-violence?

Opinions:

Majority - Mosk, J.

Yes, a trial court abuses its discretion by dismissing a prior 'strike' conviction under these circumstances. A court's power to dismiss a strike 'in furtherance of justice' is not absolute and must be guided by whether the defendant may be deemed outside the spirit of the Three Strikes law. The court's analysis must be individualized, balancing society's interest in the fair prosecution of crime against the defendant's rights. The court must consider the nature of the present felony, the prior serious/violent felony convictions, and the defendant's background, character, and prospects. Here, the trial court's decision fell 'outside the bounds of reason' because it ignored Williams's continuous, lengthy, and recent criminal history, which included violent offenses like spousal battery. The court's focus on the 13-year age of the prior strikes was improper given that Williams did not refrain from criminal activity during that time. Furthermore, the dismissal was procedurally ineffective because the court failed to set forth its reasons in a minute order as mandated by § 1385(a). The proper remedy is to vacate the judgment and allow Williams to withdraw his guilty plea, which was induced by the court's stated willingness to strike the prior.

Concurring-in-part-and-dissenting-in-part - Baxter, J.

Yes, the trial court abused its discretion as defendant's unabated criminal history, including recent violent conduct and dangerous DUI offenses, places him squarely within the spirit of the Three Strikes law. The dismissal was also procedurally ineffective for failing to enter reasons in the minutes. However, the majority is wrong to require that Williams be permitted to withdraw his guilty plea. Williams entered an 'open plea' with no promises of leniency; the judge's musings on a potential sentence do not constitute a promise that would justify automatic withdrawal. A defendant's hope for leniency that is not realized is not sufficient grounds to withdraw a plea. The matter should be remanded, and any motion to withdraw the plea should be left to the trial court's discretion, requiring Williams to show good cause.

Analysis:

This case significantly refines the holding of People v. Superior Court (Romero), which established a trial court's authority to dismiss 'strikes.' Williams provides the substantive test for exercising that authority, focusing on whether the defendant falls 'outside the spirit' of the Three Strikes law. It curtails trial court discretion by requiring a holistic review of the defendant's entire criminal history, not just isolated factors like the age of prior convictions. The decision solidifies the standard of appellate review as abuse of discretion but demonstrates that this standard is not toothless, as courts must provide a reasoned explanation for why a career criminal should not be subject to the law's full effect.

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