fundamental due process rule (California) · Go Syfert
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fundamental due process rule in California

18 California opinions name it 2 courts 1976–2015 0 in the last five years

The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (12)

CaseFollowedCited
People v. Thomasgreen
cal · 1978 · cited in 3 California opinions naming this issue, 1988–1990
2 sentences

1990As stated in People v. Van Hoek, supra, 200 Cal. App.3d at page 817 : "Implicit in the cases requiring specificity of charges and the charges being supported by specific testimony given at trial is the fundamental due process rule, steeped in antiquity, that the prosecution must prove a specific act and the twelve jurors must agree on one specific act." (Accord, People v. Creighton (1976) 57 Cal. App.3d 314, 320 [ 129 Cal. Rptr. 249 ], disapproved on other grounds in People v. Thomas (1978) 20 Cal.3d 457, 468 [ 143 Cal. Rptr. 215 , 573 P.2d 433 ]).) The majority purport to address this concern

1990As stated in People v. Van Hoek, supra, 200 Cal. App.3d at page 817 : "Implicit in the cases requiring specificity of charges and the charges being supported by specific testimony given at trial is the fundamental due process rule, steeped in antiquity, that the prosecution must prove a specific act and the twelve jurors must agree on one specific act." (Accord, People v. Creighton (1976) 57 Cal. App.3d 314, 320 [ 129 Cal. Rptr. 249 ], disapproved on other grounds in People v. Thomas (1978) 20 Cal.3d 457, 468 [ 143 Cal. Rptr. 215 , 573 P.2d 433 ]).) The majority purport to address this concern

33
Bellizzi v. Superior Courtgreen
cal · 1974 · cited in 4 California opinions naming this issue, 1976–1988
2 sentences

1988The court in People v. Mejia, supra, 57 Cal.App.3d at page 579 [ 129 Cal.Rptr. 192 ], held that if “state action has made a material witness unavailable, dismissal is mandated by due process and a defendant’s constitutional right to a fair trial.” In discussing the principles involved in its decision, the court quoted from Bellizzi v. Superior Court (1974) 12 Cal. 3d 33, 36 [ 115 Cal.Rptr. 52 , 524 P.2d 148 ]: ‘“The fundamental due process principle ... is that the prosecution may not deprive an accused of the opportunity [original italics] to present material evidence which might prove his in

1988The court in People v. Mejia, supra, 57 Cal.App.3d at page 579 [ 129 Cal.Rptr. 192 ], held that if “state action has made a material witness unavailable, dismissal is mandated by due process and a defendant’s constitutional right to a fair trial.” In discussing the principles involved in its decision, the court quoted from Bellizzi v. Superior Court (1974) 12 Cal. 3d 33, 36 [ 115 Cal.Rptr. 52 , 524 P.2d 148 ]: ‘“The fundamental due process principle ... is that the prosecution may not deprive an accused of the opportunity [original italics] to present material evidence which might prove his in

24
People v. Mejiagreen
calctapp · 1976 · cited in 3 California opinions naming this issue, 1983–1988
2 sentences

1988The court in People v. Mejia, supra, 57 Cal.App.3d at page 579 [ 129 Cal.Rptr. 192 ], held that if “state action has made a material witness unavailable, dismissal is mandated by due process and a defendant’s constitutional right to a fair trial.” In discussing the principles involved in its decision, the court quoted from Bellizzi v. Superior Court (1974) 12 Cal. 3d 33, 36 [ 115 Cal.Rptr. 52 , 524 P.2d 148 ]: ‘“The fundamental due process principle ... is that the prosecution may not deprive an accused of the opportunity [original italics] to present material evidence which might prove his in

1988The court in People v. Mejia, supra, 57 Cal.App.3d at page 579 [ 129 Cal.Rptr. 192 ], held that if “state action has made a material witness unavailable, dismissal is mandated by due process and a defendant’s constitutional right to a fair trial.” In discussing the principles involved in its decision, the court quoted from Bellizzi v. Superior Court (1974) 12 Cal. 3d 33, 36 [ 115 Cal.Rptr. 52 , 524 P.2d 148 ]: ‘“The fundamental due process principle ... is that the prosecution may not deprive an accused of the opportunity [original italics] to present material evidence which might prove his in

23
Cleveland Board of Education v. Loudermillgreen
scotus · 1985 · cited in 2 California opinions naming this issue, 2013–2015
2 sentences

2015(Cleveland Bd. of Education v. Loudermill (1985) 470 U.S. 532, 546 [ 84 L.Ed.2d 494 ].) “The opportunity to present reasons, either in person or in writing, why proposed action should not be taken is a fundamental due process requirement.” (Ibid.) Here, defense counsel actually presented to the court defendant’s request for immediate release despite the two-step process of section 1026.2.

2015(Cleveland Bd. of Education v. Loudermill (1985) 470 U.S. 532, 546 [ 84 L.Ed.2d 494 ].) “The opportunity to present reasons, either in person or in writing, why proposed action should not be taken is a fundamental due process requirement.” (Ibid.) Here, defense counsel actually presented to the court defendant’s request for immediate release despite the two-step process of section 1026.2.

22
People v. Creightongreen
calctapp · 1976 · cited in 3 California opinions naming this issue, 1988–1990
2 sentences

1990As stated in People v. Van Hoek, supra, 200 Cal. App.3d at page 817 : "Implicit in the cases requiring specificity of charges and the charges being supported by specific testimony given at trial is the fundamental due process rule, steeped in antiquity, that the prosecution must prove a specific act and the twelve jurors must agree on one specific act." (Accord, People v. Creighton (1976) 57 Cal. App.3d 314, 320 [ 129 Cal. Rptr. 249 ], disapproved on other grounds in People v. Thomas (1978) 20 Cal.3d 457, 468 [ 143 Cal. Rptr. 215 , 573 P.2d 433 ]).) The majority purport to address this concern

1990As stated in People v. Van Hoek, supra, 200 Cal. App.3d at page 817 : "Implicit in the cases requiring specificity of charges and the charges being supported by specific testimony given at trial is the fundamental due process rule, steeped in antiquity, that the prosecution must prove a specific act and the twelve jurors must agree on one specific act." (Accord, People v. Creighton (1976) 57 Cal. App.3d 314, 320 [ 129 Cal. Rptr. 249 ], disapproved on other grounds in People v. Thomas (1978) 20 Cal.3d 457, 468 [ 143 Cal. Rptr. 215 , 573 P.2d 433 ]).) The majority purport to address this concern

13
Bell v. Bursongreen
scotus · 1971 · cited in 1 California opinions naming this issue, 2005–2005
2 sentences

2005See Bell v. Burson [(1971)] 402 U.S. [535,] 540 [ 29 L.Ed.2d 90 , 91 S.Ct., 1586, 1590 ].” (Cleveland Board of Education v. Loudermill, supra, 470 U.S. at pp. 545-546.) “The opportunity to present reasons, either in person or in writing, why proposed action should not be taken is a fundamental due process requirement.

2005See Bell v. Burson [(1971)] 402 U.S. [535,] 540 [ 29 L.Ed.2d 90 , 91 S.Ct., 1586, 1590 ].” (Cleveland Board of Education v. Loudermill, supra, 470 U.S. at pp. 545-546.) “The opportunity to present reasons, either in person or in writing, why proposed action should not be taken is a fundamental due process requirement.

11
People v. Haytongreen
calctapp · 1979 · cited in 1 California opinions naming this issue, 1988–1988
2 sentences

1988Therefore, the issues raised by appellant are not cognizable on an appeal from a judgment entered upon a guilty plea.” (People v. Hayton (1979) 95 Cal.App.3d 413, 419 [ 156 Cal.Rptr. 426 ], italics added.) Hayton concerned the appealability of a trial court error in denying defendant’s motion to dismiss based on an asserted deprivation of his right to a speedy trial and to due process.

1988Therefore, the issues raised by appellant are not cognizable on an appeal from a judgment entered upon a guilty plea.” (People v. Hayton (1979) 95 Cal.App.3d 413, 419 [ 156 Cal.Rptr. 426 ], italics added.) Hayton concerned the appealability of a trial court error in denying defendant’s motion to dismiss based on an asserted deprivation of his right to a speedy trial and to due process.

11
Williams v. Superior Courtgreen
calctapp · 1974 · cited in 1 California opinions naming this issue, 1983–1983
2 sentences

1983(Id., at p. 577.) The appellate court affirmed, holding that in dropping the charges against the illegal alien witnesses and making them available for deportation without notifying the defendant, the state had made material witnesses unavailable to the defendant, stating: “If . . . state action has made a material witness unavailable, dismissal is mandated by due process and a defendant’s constitutional right to a fair trial. . . . ‘The fundamental due process principle ... is that the prosecution may not deprive an accused of the opportunity to present material evidence which might prove his

1983(Id., at p. 577.) The appellate court affirmed, holding that in dropping the charges against the illegal alien witnesses and making them available for deportation without notifying the defendant, the state had made material witnesses unavailable to the defendant, stating: “If . . . state action has made a material witness unavailable, dismissal is mandated by due process and a defendant’s constitutional right to a fair trial. . . . ‘The fundamental due process principle ... is that the prosecution may not deprive an accused of the opportunity to present material evidence which might prove his

11
People v. Golidaygreen
cal · 1973 · cited in 1 California opinions naming this issue, 1983–1983
2 sentences

1983(Id., at p. 577.) The appellate court affirmed, holding that in dropping the charges against the illegal alien witnesses and making them available for deportation without notifying the defendant, the state had made material witnesses unavailable to the defendant, stating: “If . . . state action has made a material witness unavailable, dismissal is mandated by due process and a defendant’s constitutional right to a fair trial. . . . ‘The fundamental due process principle ... is that the prosecution may not deprive an accused of the opportunity to present material evidence which might prove his

1983(Id., at p. 577.) The appellate court affirmed, holding that in dropping the charges against the illegal alien witnesses and making them available for deportation without notifying the defendant, the state had made material witnesses unavailable to the defendant, stating: “If . . . state action has made a material witness unavailable, dismissal is mandated by due process and a defendant’s constitutional right to a fair trial. . . . ‘The fundamental due process principle ... is that the prosecution may not deprive an accused of the opportunity to present material evidence which might prove his

11
People v. Garciagreen
cal · 1967 · cited in 1 California opinions naming this issue, 1983–1983
2 sentences

1983(Id., at p. 577.) The appellate court affirmed, holding that in dropping the charges against the illegal alien witnesses and making them available for deportation without notifying the defendant, the state had made material witnesses unavailable to the defendant, stating: “If . . . state action has made a material witness unavailable, dismissal is mandated by due process and a defendant’s constitutional right to a fair trial. . . . ‘The fundamental due process principle ... is that the prosecution may not deprive an accused of the opportunity to present material evidence which might prove his

1983(Id., at p. 577.) The appellate court affirmed, holding that in dropping the charges against the illegal alien witnesses and making them available for deportation without notifying the defendant, the state had made material witnesses unavailable to the defendant, stating: “If . . . state action has made a material witness unavailable, dismissal is mandated by due process and a defendant’s constitutional right to a fair trial. . . . ‘The fundamental due process principle ... is that the prosecution may not deprive an accused of the opportunity to present material evidence which might prove his

11
People v. Perezgreen
cal · 1965 · cited in 1 California opinions naming this issue, 1983–1983
2 sentences

1983(Id., at p. 577.) The appellate court affirmed, holding that in dropping the charges against the illegal alien witnesses and making them available for deportation without notifying the defendant, the state had made material witnesses unavailable to the defendant, stating: “If . . . state action has made a material witness unavailable, dismissal is mandated by due process and a defendant’s constitutional right to a fair trial. . . . ‘The fundamental due process principle ... is that the prosecution may not deprive an accused of the opportunity to present material evidence which might prove his

1983(Id., at p. 577.) The appellate court affirmed, holding that in dropping the charges against the illegal alien witnesses and making them available for deportation without notifying the defendant, the state had made material witnesses unavailable to the defendant, stating: “If . . . state action has made a material witness unavailable, dismissal is mandated by due process and a defendant’s constitutional right to a fair trial. . . . ‘The fundamental due process principle ... is that the prosecution may not deprive an accused of the opportunity to present material evidence which might prove his

11
United States v. Valenzuela-Bernalgreen
scotus · 1982 · cited in 1 California opinions naming this issue, 1983–1983
2 sentences

1983(Id., at pp. 580-581.) Real party in interest contends that the test of materiality enunciated in Mejia has been changed by the recent Supreme Court of the United States case of United States v. Valenzuela-Bernal (1982) 458 U.S. 858, 873 [ 73 L.Ed.2d 1193, 1206-1207 , 102 S.Ct. 3440, 3449 ].

1983(Id., at pp. 580-581.) Real party in interest contends that the test of materiality enunciated in Mejia has been changed by the recent Supreme Court of the United States case of United States v. Valenzuela-Bernal (1982) 458 U.S. 858, 873 [ 73 L.Ed.2d 1193, 1206-1207 , 102 S.Ct. 3440, 3449 ].

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in California. Read the followed side critically anyway.

Also cited on this issue (11)

CaseCitedYears
People v. Van Hoek green
calctapp · 1988
2 sentences

1993The Fifth District found the failure to allege and prove specific acts of molestation constituted a deprivation of due process because the defendant was not afforded an opportunity to prepare an adequate defense. ( 200 Cal.App.3d at p. 818 .) The Fifth District also found that it was impossible for the jury to unanimously agree upon any specific acts to support a conviction under section 288 when testimony of the victim is generic and consequently unspecific as to time or place. ( 200 Cal.App.3d at p. 816 .) “Implicit in the cases requiring specificity of charges and the charges being supporte

1993The Fifth District found the failure to allege and prove specific acts of molestation constituted a deprivation of due process because the defendant was not afforded an opportunity to prepare an adequate defense. ( 200 Cal.App.3d at p. 818 .) The Fifth District also found that it was impossible for the jury to unanimously agree upon any specific acts to support a conviction under section 288 when testimony of the victim is generic and consequently unspecific as to time or place. ( 200 Cal.App.3d at p. 816 .) “Implicit in the cases requiring specificity of charges and the charges being supporte

61988–1993
People v. Williams green
cal · 1901
2 sentences

1993The Fifth District found the failure to allege and prove specific acts of molestation constituted a deprivation of due process because the defendant was not afforded an opportunity to prepare an adequate defense. ( 200 Cal.App.3d at p. 818 .) The Fifth District also found that it was impossible for the jury to unanimously agree upon any specific acts to support a conviction under section 288 when testimony of the victim is generic and consequently unspecific as to time or place. ( 200 Cal.App.3d at p. 816 .) “Implicit in the cases requiring specificity of charges and the charges being supporte

1993The Fifth District found the failure to allege and prove specific acts of molestation constituted a deprivation of due process because the defendant was not afforded an opportunity to prepare an adequate defense. ( 200 Cal.App.3d at p. 818 .) The Fifth District also found that it was impossible for the jury to unanimously agree upon any specific acts to support a conviction under section 288 when testimony of the victim is generic and consequently unspecific as to time or place. ( 200 Cal.App.3d at p. 816 .) “Implicit in the cases requiring specificity of charges and the charges being supporte

41988–1993
People v. Castro green
cal · 1901
2 sentences

1993The Fifth District found the failure to allege and prove specific acts of molestation constituted a deprivation of due process because the defendant was not afforded an opportunity to prepare an adequate defense. ( 200 Cal.App.3d at p. 818 .) The Fifth District also found that it was impossible for the jury to unanimously agree upon any specific acts to support a conviction under section 288 when testimony of the victim is generic and consequently unspecific as to time or place. ( 200 Cal.App.3d at p. 816 .) “Implicit in the cases requiring specificity of charges and the charges being supporte

1993The Fifth District found the failure to allege and prove specific acts of molestation constituted a deprivation of due process because the defendant was not afforded an opportunity to prepare an adequate defense. ( 200 Cal.App.3d at p. 818 .) The Fifth District also found that it was impossible for the jury to unanimously agree upon any specific acts to support a conviction under section 288 when testimony of the victim is generic and consequently unspecific as to time or place. ( 200 Cal.App.3d at p. 816 .) “Implicit in the cases requiring specificity of charges and the charges being supporte

41988–1993
Southern California Underground Contractors, Inc. v. City of San Diego green
calctapp · 2003
2 sentences

2014(See, e.g., Southern Cal. Underground Contractors, Inc. v. City of San Diego (2003) 108 Cal.App.4th 533, 543 , citing Mathews v. Eldridge (1976) 424 U.S. 319, 333 .) In Southern Cal. Underground Contractors, this court explained that due process " ' "is not a technical conception with a fixed content unrelated to time, place and circumstance." [Citation.]' [Citation.] Rather, it ' "is flexible and calls for such procedural protections as the particular situation demands." ' " (Southern Cal. Underground Contractors, 108 Cal.App.4th at p. 543 .) As we explain, we cannot say under the present cir

2014(See, e.g., Southern Cal. Underground Contractors, Inc. v. City of San Diego (2003) 108 Cal.App.4th 533, 543 , citing Mathews v. Eldridge (1976) 424 U.S. 319, 333 .) In Southern Cal. Underground Contractors, this court explained that due process " ' "is not a technical conception with a fixed content unrelated to time, place and circumstance." [Citation.]' [Citation.] Rather, it ' "is flexible and calls for such procedural protections as the particular situation demands." ' " (Southern Cal. Underground Contractors, 108 Cal.App.4th at p. 543 .) As we explain, we cannot say under the present cir

12014–2014
Mathews v. Eldridge green
scotus · 1976
1 sentence

2014(See, e.g., Southern Cal. Underground Contractors, Inc. v. City of San Diego (2003) 108 Cal.App.4th 533, 543 , citing Mathews v. Eldridge (1976) 424 U.S. 319, 333 .) In Southern Cal. Underground Contractors, this court explained that due process " ' "is not a technical conception with a fixed content unrelated to time, place and circumstance." [Citation.]' [Citation.] Rather, it ' "is flexible and calls for such procedural protections as the particular situation demands." ' " (Southern Cal. Underground Contractors, 108 Cal.App.4th at p. 543 .) As we explain, we cannot say under the present cir

12014–2014
Applebaum v. Board of Directors of Barton Memorial Hospital green
calctapp · 1980
1 sentence

2013(Applebaum v. Board of Directors (1980) 104 Cal.App.3d 648, 656-657 .) However, “[t]he distinction between fair procedure and due process rights appears to be one of origin and not of the extent of protection afforded an individual; the essence of both rights is fairness.

12013–2013
Coleman v. DEPARTMENT OF PERSONNEL ADMININISTRATION green
cal · 1991
2 sentences

2000The tenured public employee is entitled to oral or written notice of the charges against him, an explanation of the employer’s evidence, and an opportunity to present his side of the story.” { Loudermill, supra, 470 U.S. at pp. 542-546 [105 S.Ct. at pp. 1493-1495], citations and fns. omitted.) 8 While Shelly and Loudermill involved employees who had been discharged, our Supreme Court faced a different set of circumstances in Coleman v. Department of Personnel Administration (1991) 52 Cal.3d 1102 [ 278 Cal.Rptr. 346 , 805 P.2d 300 ].

2000The tenured public employee is entitled to oral or written notice of the charges against him, an explanation of the employer’s evidence, and an opportunity to present his side of the story.” { Loudermill, supra, 470 U.S. at pp. 542-546 [105 S.Ct. at pp. 1493-1495], citations and fns. omitted.) 8 While Shelly and Loudermill involved employees who had been discharged, our Supreme Court faced a different set of circumstances in Coleman v. Department of Personnel Administration (1991) 52 Cal.3d 1102 [ 278 Cal.Rptr. 346 , 805 P.2d 300 ].

12000–2000
People v. Jones green
cal · 1990
1 sentence

1992(Id. at p. 816.) “Implicit in the cases requiring specificity of charges and the charges being supported by specific testimony given at trial is the fundamental due process rule, steeped in antiquity, that the prosecution must prove a specific act and the twelve jurors must agree on one specific act.” (Id. at p. 817 relying on People v. Williams (1901) 133 Cal. 165 [ 65 P. 323 ] and People v. Castro (1901) 133 Cal. 11 [ 65 P. 13 ].) While the Legislature responded to Van Hoek by creating a new crime, the Supreme Court abrogated its holding in People v. Jones, supra, 51 Cal.3d 294, 320-321 .

11992–1992
People v. Moreno green
calctapp · 1989
1 sentence

1990(People v. Castro, 133 Cal. 11 [ 65 P. 13 ], and People v. Williams, 133 Cal. 165 [ 65 P. 323 ].) “Implicit in the cases requiring specificity of charges and the charges being supported by specific testimony given at trial is the fundamental due process rule, steeped in antiquity, that the prosecution must prove a specific act and the twelve jurors must agree on one specific act.” (Van Hoek, supra, 200 Cal.App.3d at p. 817 ; People v. Moreno, supra, 211 Cal.App.3d at p. 789 .) The holdings in both Castro and Williams were that the prosecution may not rely on testimony that acts of unlawful sex

11990–1990
People v. Atkins green
calctapp · 1988
2 sentences

1989Relying upon these cases, the Fifth District in Van Hoek and again in People v. Atkins, supra, 203 Cal.App.3d 15 , observed that “[ijmplicit in the cases requiring specificity of charges and the charges being supported by specific testimony given at trial is the fundamental due process rule, steeped in antiquity, that the prosecution must prove a specific act and the twelve jurors must agree on one specific act.” (Van Hoek, supra, 200 Cal.App.3d at p. 817 ; Atkins, supra, 203 Cal.App.3d at p. 22 .) Appellant concedes that “[i]n the ordinary situation, where testimony shows more than one specif

1989Relying upon these cases, the Fifth District in Van Hoek and again in People v. Atkins, supra, 203 Cal.App.3d 15 , observed that “[ijmplicit in the cases requiring specificity of charges and the charges being supported by specific testimony given at trial is the fundamental due process rule, steeped in antiquity, that the prosecution must prove a specific act and the twelve jurors must agree on one specific act.” (Van Hoek, supra, 200 Cal.App.3d at p. 817 ; Atkins, supra, 203 Cal.App.3d at p. 22 .) Appellant concedes that “[i]n the ordinary situation, where testimony shows more than one specif

11989–1989
People v. Kiihoa green
cal · 1960
2 sentences

1976Even if the prosecution’s motives are ‘praiseworthy,’ they cannot prevail when they ‘inevitably result, intentionally or unintentionally, in depriving the defendant of a fair trial.’ [citing People v. Kiihoa, 53 Cal.2d 748 ( 3 Cal.Rptr. 1 , 349 P.2d 673 )].” Generally speaking the People may select and choose which witnesses they wish to use to prove their case against a defendant.

1976Even if the prosecution’s motives are ‘praiseworthy,’ they cannot prevail when they ‘inevitably result, intentionally or unintentionally, in depriving the defendant of a fair trial.’ [citing People v. Kiihoa, 53 Cal.2d 748 ( 3 Cal.Rptr. 1 , 349 P.2d 673 )].” Generally speaking the People may select and choose which witnesses they wish to use to prove their case against a defendant.

11976–1976

Statutes the citing opinions construe

CA § Cal. Penal Code § 288 (5)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 18 (1976–2015) OH 11 (1990–2020) IL 9 (1993–2014) NY 9 (1976–2019) LA 9 (1985–2025) WA 8 (2004–2024) PA 7 (1978–2019) KS 6 (1992–2012) TN 5 (1998–2016) IN 5 (1991–2019) CT 4 (1986–2022) FL 4 (1983–2021) MI 4 (1975–2024) HI 3 (1995–2017) NM 3 (1975–1989) IA 3 (2021–2025) AL 3 (2004–2014) WI 3 (1975–2024) TX 2 (1996–2013) NC 2 (2021–2021) VT 2 (1996–2008) MT 2 (1991–2025) MO 2 (2005–2005) ME 2 (1987–2016) MN 2 (1984–2001) AZ 2 (2017–2026)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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