California v. VandiverAnnotate this Case
Respondent Angela Vandiver pled guilty in 2012 to a single felony count of receiving stolen property based on her possession of blank checks she knew had been stolen. She later petitioned to have the conviction redesignated a misdemeanor under the new provisions of Proposition 47 on the ground the checks were worth $950 or less. The State opposed, arguing the balance of the victim’s checking account was greater than $950. The trial court found the value of the blank checks to be de minimis and granted the petition. The State contended the court erred by: (1) reaching the merits because Vandiver did not attach evidence of value to her petition; and (2) determining the checks’ value was de minimis. The State contended the trial court should have dismissed the petition as unsupported or found the checks were worth the full amount in the linked checking account and denied the petition on the merits. Finding no reversible error, the Supreme Court affirmed the trial court.