Thursday, April 09, 2020

People v. Maya (Cal. Supreme Ct. - April 9, 2020)

There aren't many shorter opinions than this one today from the California Supreme Court.

It'll take me almost as long to summarize the opinion as the opinion itself.  There's a statute that says you can get your misdemeanor expunged if (among other things) you've lived an "honest and upright life."  Mr. Maya was convicted of a misdemeanor, and, since then, has been either in prison or in custody for immigration reasons -- but says he's lived an honest and upright life since then, having participated in (among other things) fire camp and Alcoholics Anonymous.

The trial court and the Court of Appeal held he's not eligible because he's been in custody the whole time, so you can't really tell whether he'd be good on the outside -- essentially deciding that people in this position are categorically ineligible for relief under the statute.  The California Supreme Court granted review, and in the briefs, the Attorney General abandoned his previous position that it the statute was categorically inapplicable in such settings, arguing only that this particular person should be denied on the merits.

The California Supreme Court basically says:  "Thanks for doing all the work for us."  It unanimously holds that, consistent with the concession, yes, it's possible for someone to be eligible for relief under the statute even if they've been in custody the whole time.  Then it just simply refuses to decide whether or not this particular person is eligible for relief, remanding that issue to the Court of Appeal.

That definitely resolves the issue.  In around five very succinct pages.  Though it leaves entirely open the more central question:  "Okay, so the statute's not categorically inapplicable.  But how does one in fact apply the thing to people who've been in custody the whole time?  How much does that weigh in deciding whether they'll live an 'honest and upright life' on the outside?"

That's the harder question.  It's also the one that, practically, matters.  And on that central point, the California Supreme Court says absolutely nothing.

The price of unanimity and speed here may be that, given the concession, we've resolve the tangential dispute, but not helped at all to decide what's really at issue and what motivated the decision below.

But, hey.  It's five pages.  An easy read.