Yates

People v. Yates

Good Law
235 Cal. Rptr. 3d 756·25 Cal. App. 5th 474
Court of Appeal of CaliforniaJuly 23, 2018B279863California5,878 words

Opinion

lead Opinion

Lui, J.

*476 This case presents the following issue: May an expert relate as true the case-specific content of documents which were neither admitted into evidence nor shown to be covered by a hearsay exception? We conclude under People v. Sanchez (2016) 63 Cal.4th 665 , 684-686, 204 Cal.Rptr.3d 102 , 374 P.3d 320 ( Sanchez ), that such testimony is inadmissible.

A jury found David Yates (Yates) to be a sexually violent predator (SVP) under the Sexually Violent Predators Act (the SVP Act or the Act). ( Welf. & Inst. Code, § 6600 et seq. ) 1 Yates contends the jury's finding must be overturned because the trial court committed numerous prejudicial errors under Sanchez , including erroneously permitting the experts to testify to a massive amount of inadmissible case-specific hearsay. We agree that the trial court misapplied Sanchez and erroneously allowed the People's experts to relate as true case-specific facts contained in hearsay statements, which were not covered by a hearsay exception or independently proven by competent evidence. ( Sanchez , supra , 63 Cal.4th at p. 686 , 204 Cal.Rptr.3d 102 , 374 P.3d 320 .) Because that testimony was prejudicial, we reverse.

*477 PROCEDURAL…

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