People v. Williams CA4/1

DISCUSSION

I. Probation Conditions

A. General Legal Principles

A probation condition is invalid if it (1) is not related to the crime of which the

offender was convicted, (2) relates to noncriminal conduct, and (3) requires or forbids

conduct which is not reasonably related to future criminality. (People v. Lent (1975)

Cal.3d 481, 486 (Lent).) All three parts of the Lent reasonableness test must be satisfied

before a reviewing court will invalidate a condition of probation. (People v. Olguin

(2008) 45 Cal.4th 375, 379.) Probation conditions should be given " 'the meaning that

would appear to a reasonable, objective reader.' " (Id. at p. 382.)

3 A challenge to a probation condition based on the Lent unreasonableness factors is

forfeited on appeal if the defendant fails to object on that ground in the trial court.

(People v. Welch (1993) 5 Cal.4th 228, 234-238.) However, a defendant may raise on

appeal, without having objected in the trial court, an appellate claim amounting to a

" 'facial challenge' " based on a constitutional defect that does not require scrutiny of

individual facts and circumstances. (In re Sheena K. (2007) 40 Cal.4th 875,…