People v. Williams CA4/1

California Court of Appeal · D078777 · 2021-08-30 · Unpublished

Proceeding: appeal from a judgment
Trial court: Superior Court of San Diego County · No. SCN316186
Trial judge: Brad A. Weinreb
Outcome: affirmed — Affirmed.
Area: criminal
Panel: Richard D. Huffman, Sr. (author), Judith L. Haller, Joan K. Irion

Analysis

A model's reading — qwen3.8-27b, prompt v1, 2026-10-13T05:02Z · confidence low

The trial court revoked Williams's probation and sentenced him to two years in state prison after he admitted to violating probation terms. The Court of Appeal affirmed the judgment, finding no arguable issues for reversal after a Wende review of the record.

Ruling reviewed	Standard	The court	The model
Revocation of probation and imposition of a two-year state prison sentence “We have reviewed the entire record as required by Wende and Anders. We have not discovered any arguable issues for reversal on appeal.”	unclear	not reached	unsure The opinion is a Wende review where the court states it found no arguable issues. It does not explicitly analyze the specific legal standards for probation revocation or sentencing discretion, nor does it address the specific arguments raised by counsel regarding due process or factual basis. Therefore, the appellate court's view on the specific merits is not detailed, and the standard of review is not explicitly stated for the underlying trial court actions.

Authorities

relied: People v. Wende (1979) 25 Cal.3d 436 — Requires appointed appellate counsel to review the record for error when a defendant has not filed a brief.
relied: Anders v. California (1967) 386 U.S. 738 — Requires counsel to identify arguable issues and file a brief when they believe an appeal is frivolous.

The appellate opinion: sound with gaps — The opinion is a standard Wende review where the court states it reviewed the record and found no arguable issues. It does not provide specific reasoning for why the trial court's actions were correct, nor does it address the specific legal questions raised by counsel (due process, factual basis, discretion).

How this analysis was made · dispute it

unusual disposition

A model's reading — claude-fable-5-1, prompt v1, 2026-10-13T04:30Z · confidence low

After Williams admitted violating probation in 2021, following a 2014 revocation for failing to comply with the Interstate Compact transfer to Georgia, the trial court declined to reinstate probation and sentenced him to a two-year custodial term. On appeal, appointed counsel filed a Wende brief identifying three possible issues; the Court of Appeal independently reviewed the record, found no arguable issues, and affirmed the judgment.

Ruling reviewed	Standard	The court	The model
Acceptance of Williams's admission of the probation violation without an evidentiary hearing, and adequacy of the plea advisements “Did Williams receive full due process when the trial court did not conduct an evidentiary hearing on the violation of probation and were the plea advisements adequate?”	unclear	correct	unsure The opinion does not describe the advisements given or analyze the waiver; it simply reports that independent Wende review disclosed no arguable issue. An admitted violation ordinarily dispenses with the need for a formal evidentiary hearing if the admission is knowing and voluntary, so the result is plausible, but the opinion supplies no record detail to verify it.
Finding of a sufficient factual basis for the probation-violation admission “Was there a sufficient factual basis for the violation of probation admission?”	unclear	correct	unsure The adopted statement of facts shows Williams failed to return to probation as directed on April 1, 2014, and a letter to his last address was returned undeliverable, which on its face supports a violation of the Interstate Compact conditions. The opinion does not independently analyze the point, however, so agreement rests on the sparse recited facts.
Denial of reinstatement on probation and imposition of a two-year custodial term “Did the trial court abuse its discretion in denying reinstatement of probation and sentencing Williams to two years in state prison?”	abuse of discretion	correct	unsure Williams had two prior admitted violations, absconded from the Interstate Compact process in 2014, and was not before the court again until 2021 after an intervening Arizona incarceration; a decision not to reinstate probation on that history is comfortably within a trial court's discretion, and the two-year term is a middle-term sentence for the underlying offenses. The opinion does not explain its reasoning, so the conclusion is inferred from the recited history rather than from the court's analysis.

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 to determine whether any arguable issue exists.
relied: Anders v. California (1967) 386 U.S. 738 — Appointed counsel who finds an appeal without merit may so advise the court but must identify anything in the record that might arguably support the appeal, and the court must then review the record.

The appellate opinion: sound — The court followed the Wende/Anders procedure: counsel identified possible issues, the defendant was invited to file a supplemental brief, and the court states it independently reviewed the entire record and found no arguable issue, which is all the procedure requires. The opinion offers no substantive analysis of the three identified issues, but a Wende affirmance is not required to do so, so the result is defensible on the sparse record recited.

How this analysis was made · dispute it

record incomplete

Opinion

Filed 8/30/21 P. v. Williams 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, D078777

Plaintiff and Respondent, v. (Super. Ct. No. SCN316186)

LONDON HAILEY WILLIAMS,

Defendant and Appellant.

APPEAL from a judgment of the Superior Court of San Diego County, Brad A. Weinreb, Judge. Affirmed. Matthew Aaron Lopas, under appointment by the Court of Appeal, for Defendant and Appellant. No appearance for Plaintiff and Respondent. In 2013, London Hailey Williams pleaded guilty to the unlawful taking of a vehicle (Veh. Code, § 10851, subd. (a)) and dissuading a witness (Pen. Code, § 136.1, subd. (b)(1)). Williams was placed on probation. In September 2013, Williams admitted violating probation. He was reinstated to probation. In January 2014, Williams again admitted a probation violation. He was reinstated to probation. In March 2014, the court granted Williams’s request to move to Georgia pursuant to the Interstate Compact. Williams did not comply with the terms of the move; probation was revoked, and a bench warrant was issued. In March 2021, Williams admitted his violation of probation. He was sentenced to a two-year term in custody. Williams filed a timely notice of appeal. Appellate counsel has filed a brief pursuant to People v. Wende (1979) 25 Cal.3d 436 (Wende). Counsel asks the court to review the record for error as mandated by Wende. We offered Williams the opportunity to file his own brief on appeal, but he has not responded. STATEMENT OF FACTS Appellant’s opening brief contains an accurate statement of the factual and procedural background of this case. We will adopt that summary here for convenience. “On March 26, 2014, Williams appeared before the [c]ourt, wherein the [c]ourt granted his request to move to Georgia pursuant to ICSU. Subsequently, Williams reported to the probation office, where he was informed of the ICSU process and directed to return on April 1, 2014. Williams did not return. On April 7, 2014, the probation department mailed an appointment letter to Williams’[s] last reported address, which was returned as undeliverable. On April 25, 2014, the San Diego County Probation Department filed an ex parte petition for revocation of probation and issuance of a bench warrant, citing Williams’[s] failure to comply with the ICSU process. The petition was signed by the [c]ourt the same day. On April 28, 2014, Williams contacted San Diego Probation Officer Erik Schick to 2 report that he had moved to Georgia as planned and was living with his mother. “Between 2016 and 2019, Williams was incarcerated in the state of Arizona. According to his parole officer, Williams was living with his aunt, reporting to parole as directed, and gainfully employed. He also completed an anger management class. Williams was discharged early from parole based on his good performance.” DISCUSSION As we have noted, appellate counsel has filed a Wende brief and asks the court to 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 the following possible issues that were considered in evaluating the potential merits of this appeal. 1. Did Williams receive full due process when the trial court did not conduct an evidentiary hearing on the violation of probation and were the plea advisements adequate? 2. Was there a sufficient factual basis for the violation of probation admission? 3. Did the trial court abuse its discretion in denying reinstatement of probation and sentencing Williams to two years in state prison? We have reviewed the entire record as required by Wende and Anders. We have not discovered any arguable issues for reversal on appeal. Competent counsel has represented Williams on this appeal.

3 DISPOSITION The judgment is affirmed.

HUFFMAN, Acting P. J.

WE CONCUR:

HALLER, J.

IRION, J.

Cites, in this corpus

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