People v. Jackson CA4/1

California Court of Appeal · D086403 · 2026-07-06 · Unpublished

Proceeding: appeal from a judgment
Trial court: Superior Court of San Diego County · No. SCD304666
Trial judge: Polly H. Shamoon
Outcome: affirmed — Affirmed.
Area: criminal
Panel: Michele M. Castillo (author), Laurence D. Rubin

Analysis

A model's reading — qwen3.8-27b, prompt v1, 2026-10-13T03:19Z · confidence low

The trial court accepted a guilty plea, suspended a six-year prison term, and later ordered 270 days of additional custody after the defendant admitted a probation violation. The Court of Appeal affirmed the judgment after an independent review of the record pursuant to a Wende brief.

Ruling reviewed	Standard	The court	The model
Probation revocation and imposition of 270 days additional custody “whether Jackson’s probation revocation was due to her lack of funds to pay for monitoring.”	unclear	not reached	unsure The court identified the issue but did not provide specific reasoning or a conclusion on the merits, stating only that it independently reviewed the record and found no error.

Authorities

relied: People v. Wende (1979) 25 Cal.3d 436 — Requires independent review of the record when appointed counsel files a brief identifying no arguable issues.
relied: Anders v. California (1967) 386 U.S. 738 — Requires independent review of the record when appointed counsel files a brief identifying no arguable issues.

The appellate opinion: sound with gaps — The opinion is procedurally sound in its adherence to Wende and Anders requirements for independent review. However, it is a 'sound with gaps' opinion because it identifies a specific potential issue regarding probation revocation but fails to provide any reasoning or analysis for why that issue was rejected.

How this analysis was made · dispute it

unusual disposition unusual disposition

A model's reading — claude-fable-5-1, prompt v1, 2026-10-13T04:20Z · confidence low

The trial court, after Jackson admitted violating probation on a stipulated plea to assault with a deadly weapon with a great bodily injury enhancement, ordered 270 additional days of custody and reinstated her on probation. On appeal, counsel filed a Wende brief, Jackson filed no supplemental brief, and the Court of Appeal independently reviewed the record, found no arguable issues, and affirmed.

Ruling reviewed	Standard	The court	The model
Finding of probation violation based on Jackson's admission and imposition of 270 days additional custody with reinstatement of probation “Jackson admitted the probation violation. The court ordered 270 days of additional custody and reinstated Jackson on probation.”	unclear	correct	unsure The opinion states only that the court independently reviewed the record under Wende and Anders and found no arguable issues; it does not describe the facts of the violation or analyze the disposition. Nothing in the opinion suggests legal error, and an admitted violation followed by reinstatement with additional custody is within the trial court's authority, but the opinion gives too little detail to confirm the result independently.
Possible issue identified by counsel: whether the probation revocation was based on Jackson's inability to pay for monitoring “whether Jackson’s probation revocation was due to her lack of funds to pay for monitoring.”	unclear	not reached	unsure The court listed this Anders issue but did not discuss the facts or explain why it lacks merit; it simply stated it had reviewed the record and found no error. Because the opinion contains no facts about the basis for the violation, I cannot evaluate whether the issue was properly rejected.
Grant of Jackson's request to replace appointed counsel “The court granted Jackson’s request to replace appointed counsel.”	unclear	correct	agree with court The request was granted in Jackson's favor, so it could not have prejudiced her; the court's implicit conclusion that it presents no arguable issue is sound.

Authorities

relied: People v. Wende (1979) 25 Cal.3d 436 — When appointed appellate counsel finds no arguable issues, the Court of Appeal must independently review the entire record for error before affirming.
relied: Anders v. California (1967) 386 U.S. 738 — Appointed counsel who finds an appeal frivolous may so advise the court but should identify anything in the record that might arguably support the appeal.

The appellate opinion: sound with gaps — The opinion follows the standard Wende procedure, notes the Anders issue counsel identified, confirms Jackson was invited to file her own brief, and states the record was independently reviewed, which is a defensible basis for affirmance. It is extremely sparse, however, reciting almost no facts about the violation and offering no explanation of why the inability-to-pay issue lacks merit, so the reasoning cannot be checked from the opinion itself.

How this analysis was made · dispute it

record incomplete

Opinion

Filed 7/6/26 P. v. Jackson CA4/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

COURT OF APPEAL, FOURTH APPELLATE DISTRICT

DIVISION ONE

STATE OF CALIFORNIA

THE PEOPLE, D086403

Plaintiff and Respondent, (Super. Ct. No. SCD304666)

PARIS JACKSON,

Defendant and Appellant.

APPEAL from a judgment of the Superior Court of San Diego County, Polly H. Shamoon, Judge. Affirmed. Jake E. Stanton, under appointment by the Court of Appeal, for Defendant and Appellant. No appearance by Plaintiff and Respondent. Paris Jackson entered into a plea agreement with a stipulated sentence. Jackson pleaded guilty to one count of assault with a deadly weapon (Pen. Code,1 § 245, subd. (a)(1)) and admitted personally inflicting great bodily injury (§ 12022.7, subd. (a)).

1 Further statutory references are to the Penal Code. Pursuant to a stipulation, the court ordered a suspended six-year prison term and granted formal probation. The court ordered Jackson into custody pending a hearing on her possible probation violation. The court granted Jackson’s request to replace appointed counsel. Jackson admitted the probation violation. The court ordered 270 days of additional custody and reinstated Jackson on probation. Jackson filed a timely notice of appeal. Appellate counsel has filed a brief under the authority of People v. Wende (1979) 25 Cal.3d 436 (Wende) indicating counsel has not been able to identify any arguable issues for reversal on appeal. Counsel asks the court to independently review the record for error as mandated by Wende. We advised Jacson that she could file her own brief on appeal, but she has not responded to our notice. DISCUSSION As we have noted, appellate counsel has filed a Wende brief and asks the court to independently review the record for error. To assist the court in its review and in compliance with Anders v. California (1967) 386 U.S. 738 (Anders) counsel has identified a possible issue that was considered in evaluating the potential merits of this appeal: whether Jackson’s probation revocation was due to her lack of funds to pay for monitoring. We have independently reviewed the record for errors as required by Wende and Anders. Competent counsel has represented Jackson in this appeal.

2 DISPOSITION The judgment is affirmed.

HUFFMAN, J.* WE CONCUR:

CASTILLO, Acting P. J.

RUBIN, J.

* Retired Associate Justice of the Court of Appeal, Fourth Appellate District, assigned by the Chief Justice pursuant to article VI, section 6 of the California Constitution. 3

Cites, in this corpus

People v. Wende Crim. 20851 · 1979-10-12