People v. Williams CA2/3

INTRODUCTION

After a court trial, defendant and appellant Briand Williams was found guilty of failing to register as a sex offender (Pen. Code, § 290.012).1 He contends the judgment must be reversed because (1) it is based on document that should have been excluded as hearsay and under Crawford v. Washington (2004) 541 U.S. 36 (Crawford); (2) the judgment is predicated on an unlawful plea in the underlying sex offense case; (3) there is insufficient evidence to show he violated section 290.012; and (4) the 14-year delay in prosecuting him violated his due process rights. We reject these contentions and affirm the judgment.

FACTUAL AND PROCEDURAL BACKGROUND

In 1996, defendant was charged with six counts of violating section 288, subdivision (c),2 in Los Angeles County Superior Court case No. BA130843 (the 288(c) case). John Helbling is a paralegal in the Los Angeles County District Attorney’s Office. His job for 18 years was to “allege[] and order[]” documents that proved prior convictions. He assembled People’s exhibit 2, consisting of, among other things: (1) a certified fingerprint card date-stamped October 29, 1995 and stating a charge of “288(c)” against Briand Bernard…