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People v. Corrales
Citation: Not availableDocket: B297181
Court: California Court of Appeal; March 10, 2020; California; State Appellate Court
Original Court Document: View Document
The California Court of Appeal addressed an appeal by Juan F. Corrales, who was convicted of misdemeanor unlawful burning after setting fire to a palm tree near a strip mall. During sentencing, the trial court imposed a stay-away order requiring Corrales to remain 100 yards away from the strip mall, citing the emotional distress experienced by witnesses. However, the court did not specify the duration of this order or the statutory authority for it. The appellate court found that the stay-away order constituted a protective order, which must comply with California Penal Code section 136.2. This section permits protective orders only during ongoing criminal proceedings and is intended to safeguard victims and witnesses, not to impose postjudgment restrictions on defendants. The People argued that the order was justified based on the court's inherent authority to protect the judicial process, referencing the case of Townsel v. Superior Court, which involved serious threats to juror safety. The appellate court clarified that the circumstances in Townsel were unique and did not support the issuance of a postjudgment protective order in this case. Consequently, the appellate court struck the stay-away order, agreeing that the trial court lacked the authority to impose it after the judgment. The Ponce court emphasized that even if a trial court invoked inherent judicial authority for its order, this would not alter the outcome due to existing statutory regulations governing restraining orders. Courts should not exercise inherent powers in ways that contradict established legislation. Statutory provisions for long-term protective orders include specific procedural protections for those affected. The Legislature intended for section 136.2 orders to have a limited scope, applicable only to prejudgment proceedings; extending their duration would encroach upon similar restraining orders available under Code of Civil Procedure section 527.6, which provides additional protections for the restrained party. Although the People may have sought intervention to protect victims based on specific circumstances, section 136.2 does not permit postjudgment restraining orders, as it is limited to orders during ongoing criminal proceedings. There are no statutes allowing unlimited postjudgment restraining orders based on a misdemeanor conviction. Consequently, the stay-away order issued by the trial court exceeds the authority of section 136.2 and is therefore stricken. The decision is certified for publication.