California v. Ranlet
Annotate this CaseA jury convicted defendant Adam Ranlet of two counts of lewd and lascivious act on a child under the age of 14 years by use of force,1 four counts of lewd and lascivious conduct on a child under the age of 14 years, and one count of attempted lewd and lascivious conduct on a child under the age of 14 years. The jury also found true the allegation the offenses were committed against two or more victims under the age of 14 years. The trial court sentenced defendant to serve a term of 93 years to life in prison. On appeal, defendant argued: (1) the trial court erred in admitting evidence of his participation in a private online discussion group called "ptcruzers" (in which participants made thinly veiled references to sexual molestations of minors); (2) the trial court should have excluded evidence that defendant showed the victim a video tape depicting the rape of a 10- to 12-year-old girl as unduly prejudicial; (3) the jury was misinstructed that his participation in the "ptcruzer" online chat group was an uncharged crime; (4) that the Court of Appeal should review the sealed documents relating to Child Protective Services (CPS) records for the victim; and (5) the Court of Appeal should strike one of his 15-years-to-life terms imposed for his two convictions of committing a lewd and lascivious act on a child under the age of 14 years by use of force against the same victim. After review, the Court of Appeal concluded the online discussion group evidence was admissible under Evidence Code section 1101, subdivision (b), to show defendant's intent to sexually molest the two victims in this case. Defendant's argument regarding admission of the video tape was not preserved for review. As to the instruction regarding the online discussion group, the Court concluded the trial court erred in stating to the jury that defendant's participation was an uncharged crime. However, the error was harmless. The Court reviewed the sealed record and determined the trial court did not err in ordering part of the CPS record to be disclosed to the parties. Finally, the Court struck one of the prison terms imposed for defendant's two convictions of section 288, subdivision (b)(1), against the same victim on the same occasion. Accordingly, the Court affirmed defendant's convictions but remanded for resentencing.
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