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Name: People v. Presley
Case #: C090439
Court: CA Court of Appeal
District 3 DCA
Opinion Date: 06/16/2021
Subsequent History: Ordered Published 6/28/21
Summary

In a court trial on defendant’s commitment as a sexually violent predator (SVP), the trial court did not abuse its discretion under People v. Sanchez (2016) 63 Cal.4th 665 in relying on expert testimony, where nothing in the record suggests the trial court failed to correctly apply the law. At the court trial on a petition to commit defendant as an SVP, the court heard testimony from four expert witnesses who had all interviewed defendant and reviewed his medical and prison records. The trial court determined defendant was an SVP. Defendant appealed, arguing his commitment was based on case-specific hearsay in violation of Sanchez. Held: Affirmed. Expert witnesses may testify about their general knowledge in a specialized area without being subject to exclusion on hearsay grounds. By contrast, an expert is precluded from relating case-specific facts about which the expert has no independent knowledge. Case-specific facts are those relating to the particular events and participants alleged to have been involved in the case being tried. An exception to the general rule barring an expert from relating case-specific hearsay has developed under the common law for medical diagnoses, as doctors often rely on patients’ hearsay descriptions of their symptoms to form diagnoses. Here, even if the trial court may have heard inadmissible case-specific hearsay, this does not overcome the presumption that the trial court applied Sanchez and properly ignored such material. In finding defendant was an SVP, the trial court did not reference any of the contested material, and the expert opinion testimony drew on multiple sources of information, not solely the case-specific facts that defendant challenged on appeal. Further, experts may rely on hearsay documents that are of a type that reasonably may be relied upon by an expert in forming an opinion upon the subject to which his testimony relates.