People v. Clason CA4/1

BACKGROUND

Ulysses Andrade was waiting in a drive-through lane at a coffee shop when he noticed flames in dumpsters behind the shop and saw Clason inside the locked enclosure surrounding the dumpsters. Clason put burning cardboard into the dumpsters and kicked burning cardboard under them. Andrade summoned law enforcement. Deputy Sheriff Chris Drouin arrived at the scene, saw the fire in the dumpsters, and saw Clason pick up burning cardboard from the ground and put it into one of the dumpsters. Police Officer Tim Biffle also arrived at the scene and saw Clason ignite cardboard and other trash that was on the ground and put it into the dumpsters. After Drouin got a key for the enclosure from the coffee shop supervisor and unlocked it, Clason exited the enclosure. Firefighters extinguished the fire. The People charged Clason with arson of property (Pen. Code, § 451, subd. (d)) and alleged as an enhancement that he had a prior felony arson conviction (id., § 451.1, subd. (a)(1)). He pled not guilty, and the case proceeded to a jury trial. Before trial, the court ruled Clason could not introduce evidence of statements he made to law enforcement officers at the scene and could not…