Brown

People v. Brown

Good Law
23 Cal. App. 5th 765·233 Cal. Rptr. 3d 256
Court of Appeal of CaliforniaMay 23, 2018A144372California4,092 words

Opinion

lead Opinion

Miller, J.

*257 *767 A jury found defendant Reginald Brown guilty of one count of continuous sexual abuse of a child under the age of 14 years old and eight counts of lewd acts upon a child under the age of 14 years. In all, there were three victims, Jane Does 1, 2, and 3. Brown's primary contention on appeal is that the six convictions of lewd acts upon Jane Doe 3 ( Pen. Code, 1 § 288, subd. (a) ) are barred by the statute of limitations.

The crimes of conviction as to victim Jane Doe 3 occurred over the course of about two years ending in 1994 when Jane Doe 3 was around 13 years old, *768 but Brown was not charged until February 2013. At the time of the offenses, the statute of limitations was six years, subject to a one-year extension when a victim first reports the offenses to law enforcement. Specifically, section 803 provides an extension of the statute of limitations for certain sex offenses-including violation of section 288-allowing the filing of a criminal complaint within one year of a report to a law enforcement agency by a person alleging he or she was the victim of such an offense under the following circumstances: (1) the victim was under 18 years of age at the time of the…

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