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People v. Means

Citations: 177 Cal. App. 3d 138; 222 Cal. Rptr. 735; 1986 Cal. App. LEXIS 2534Docket: A030169

Court: California Court of Appeal; February 4, 1986; California; State Appellate Court

Narrative Opinion Summary

In this case, the defendant, previously convicted of assault with a deadly weapon, was found guilty by a jury of arson and filing a fraudulent insurance claim. The central legal issue on appeal was whether the trial court erred in permitting the use of her prior felony convictions for impeachment purposes, should she choose to testify. The trial court held that the prior assault conviction constituted an offense involving moral turpitude under the standard set forth in People v. Castro, which characterizes crimes demonstrating a general readiness to do evil as morally turpitudinous. On appeal, the defendant argued against this determination, contending that the trial court's decision was erroneous. However, the appellate court dismissed these arguments as without merit and affirmed the lower court's judgment, thereby upholding the conviction. The court’s opinion noted compliance with the California Rules of Court, indicating selective publication of the opinion. This ruling underscores the legal principle that prior convictions involving moral turpitude are admissible for the purpose of impeachment, reinforcing judicial discretion in considering the nature and relevance of past criminal conduct.

Legal Issues Addressed

Appellate Review on Use of Prior Convictions

Application: The appellate court upheld the trial court's decision, finding the argument regarding the use of prior convictions for impeachment meritless.

Reasoning: The appellate court found Means' argument meritless and affirmed the conviction.

Definition of Moral Turpitude

Application: The court applied the definition of moral turpitude from People v. Castro, identifying crimes that demonstrate a general readiness to do evil.

Reasoning: The court ruled that the assault conviction involved 'moral turpitude,' as established in People v. Castro, which defines crimes indicating a 'general readiness to do evil' as morally turpitudinous.

Impeachment by Prior Convictions

Application: The trial court allowed the use of prior felony convictions for impeachment purposes, determining that the prior conviction constituted a crime of moral turpitude.

Reasoning: She appealed the judgment, contesting the trial court's decision to allow her prior felony convictions to be used for impeachment if she chose to testify.

Publication of Judicial Opinions

Application: The opinion was only partially published according to the California Rules of Court.

Reasoning: The opinion included a note that only certain parts would be published, following California Rules of Court.