California v. Trujillo
Annotate this CaseThe State appealed a trial court order sustaining a demurrer to the felony complaint in this case, which contended (as relevant), the complaint failed to provide sufficient notice of its charges in violation of Penal Code sections 950 and 952. The State maintained they met applicable pleading requirements. According to the People, Defendants Sabas Trujillo, Lucia Trujillo, Richard (Rick) Trujillo, Laura Fitzpatrick, and Alex Trujillo (collectively Defendants), owned or were current or former employees of three entities: United Paving, Prestige Striping, and Yeguada Trujillo, Inc. Following earlier pleading challenges, the State filed a 20-count first amended felony complaint in January 2015, alleging Defendants submitted payroll documents that underreported employee wages over a period of years to, among others, two insurance companies, the State Compensation Insurance Fund, and the Employment Development Department, for purposes of reducing insurance premiums and taxes. For each count relating to insurance and tax fraud, the State identified a particular defendant or defendants, business, the statutory provision at issue, the relevant time period (which, according to the State, generally corresponded to an insurance policy term), and the alleged victim. Defendants demurred on statute of limitations grounds, and for failure to conform to the pleading provisions the applicable statutes, contending counts were "vague and uncertain as to the charges alleged." After review of this matter, the Court of Appeal agreed with the State that it met the applicable pleading requirements, and reversed the trial court.
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