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Name: People v. England
Case #: C032080
Court: CA Court of Appeal
District 3 DCA
Opinion Date: 09/12/2000
Subsequent History: Review denied 12/20/00

Holding appellant’s jury trial on the prison grounds did not violate appellant’s right to a public trial or the Standards of Judicial Administration where the courtroom was physically and visually remote from the prison, was outside the prison wires, was accessible to the press and general public, and the only inmates jurors might have seen were tending the garden. Because the trial was on prison grounds, it was the warden, rather than the trial judge, who could determine whether any felon could attend the trial. This, however, did not violate the separation of powers clause because appellant failed to show that any felons were denied access or that the prison warden interfered with anyone attending the trial. Holding the jury trial on prison grounds did not ease the prosecution’s burden of proving appellant was confined. Appellant stipulated that he was confined, and the evidence unequivocally established that defendant was confined so that this issue could not reasonably have been contested. Trial on the prison grounds is not the functional equivalent of shackling because here, nothing about the location prejudiced the jury, affronted anyone’s dignity, or caused disrespect for the judicial system. The trial court did not abuse its discretion in excusing a juror for cause who was a retired correctional officer with high blood pressure who refused to return to the prison for any reason. Retired persons with an aversion to their workplace are not a cognizable group.