People v. Eslava
Annotate this CaseIn 2011, Eslava fatally stabbed his roommate in a San Francisco single room occupancy hotel. The court of appeal affirmed his conviction for voluntary manslaughter with a weapons use enhancement, but reversed Eslava‘s 18-year prison sentence and remanded for determination of whether a 2009 conviction for battery resulting in serious bodily injury qualified as a sentence-enhancing strike and serious felony. To determine whether the record proved beyond a reasonable doubt that Eslava personally inflicted serious bodily injury on the battery victim, the trial court examined the complaint, the transcript of the plea colloquy, and a police report. During the plea colloquy, Eslava‘s counsel had stipulated that the police report—which describes Eslava hitting the victim with a wooden stick, injuring him seriously enough to require hospitalization—supplied a factual basis for the conviction. The court reimposed the 18-year sentence. The court of appeal reversed and remanded for a jury trial on the issue of personal infliction of serious bodily injury unless Eslava waives his constitutional right to a jury determination. Since personal infliction of serious bodily injury is not inherent to the conviction, it was improper for the court—rather than a jury—to make that finding. The court noted that the law has evolved significantly since it decided the first appeal.
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