People v. White CA4/1

I. INTRODUCTION

Columbus White appeals from his convictions for human trafficking, pimping, and pandering. White claims that text messages between the prostitutes and him were inadmissible hearsay, and the People’s expert improperly relied on the truth of those texts. Finding the texts admissible under hearsay exceptions, we disagree and affirm the conviction.

II. BACKGROUND

In 2023, the Office of the San Diego District Attorney charged White with human trafficking, pimping, and pandering of minor Maria S. between January 23, 2022, and January 31, 2022 (Pen. Code, §§ 236.1, subd. (c)(1), 266h, subds. (a) & (b)(1), 266i, subds. (a)(1) & (b)(1); counts 1–3); pimping and pandering of Gabriella J. between January 8, 2022, and February 21, 2022 (id., §§ 266h, subd. (a), 266i, subd. (a)(1); counts 4–5); pimping and pandering of Juanica L. between February 2, 2022, and February 22, 2022 (id., §§ 266h, subd. (a), 266i, subd. (a)(1); counts 6–7); and pimping and pandering of Marketta G. between February 17, 2022, and February 21, 2022 (id., §§ 266h, subd. (a), 266i, subd. (a)(1); counts 8–9). At White’s trial, the trial court admitted text messages between White

and the four…