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Name: People v. Little
Case #: H024757
Court: CA Court of Appeal
District 6 DCA
Opinion Date: 02/09/2004
Subsequent History: None

Where a stipulation to certain facts is tantamount to a guilty plea, the defendant must be advised of and waive his constitutional rights. Here, the defense stipulated that the defendant had been under the influence of methamphetamine “in violation of Health and Safety Code section 11550(a).” The People argued that this was not tantamount to a guilty plea because the defendant had not admitted that he was “willfully and unlawfully” under the influence. The Court of Appeal disagreed and found the error not harmless, distinguishing People v. Howard (1992) 1 Cal.4th 1132 on the grounds that the defendant here had not yet been to trial or exercised his right to cross-examine witnesses; further, there were no advisements from which he could have reasonably inferred that by offering the stipulation he was surrendering his privilege against self-incrimination and partially surrendering his right to confront and cross-examine witnesses. Finally, the court found that sufficient evidence supported the defendant’s conviction for child endangerment, where the evidence showed that an infant had been left on a bed without rails or restraints in a house filled with garbage, rotten food, and animal feces.