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Name: People v. Collins
Case #: S075232
Court: CA Supreme Court
District CalSup
Opinion Date: 08/02/2001
Subsequent History: None
Summary

Appellant entered a guilty plea to several sex offenses. When the court accepted appellant’s waiver of a jury trial, it informed appellant that he would receive “some benefit” from his waiver, though it could not specify what that benefit would be. The appellate court determined that the jury waiver obtained under those circumstances was valid, and the Supreme Court here reversed. The trial court’s statement that appellant would receive “some benefit” to be determined at a later date amounted to an improper inducement to waive his right to a jury trial. The fact that the trial court did not specify what the benefit would be did not negate the coercive effect of the court’s assurances. The trial court, in effect, offered to reward appellant for refraining from the exercise of a constitutional right, and therefore rendered the waiver involuntary. Appellant’s volition having been compromised, there can be no application of harmless error analysis, and reversal was required.