California v. Maxwell
Annotate this CaseAnthony Maxwell was convicted by jury of possessing methadone, drug paraphernalia, and on two occasions, possessing heroin with the intent to sell it. The trial court found true several allegations that lengthened the sentence for these offenses, including that defendant had a prior “strike” conviction, served a prior prison term, and committed one of the offenses while out on bail on another offense. The court sentenced defendant to 13 years in prison. On appeal, defendant argued: (1) the trial court wrongly denied his two motions to suppress evidence; (2) the court wrongly instructed the jury about “uncharged offenses” (that is, offenses that were discussed but not charged in this case); and (3) the court wrongly imposed several sentencing enhancements: an “on bail” enhancement - which the court imposed because defendant committed one of the offenses here while out on bail on another offense - and a prior prison term enhancement - which the court imposed because defendant served a prior prison term shortly before he committed the offenses here. After review of the trial court record, the Court of Appeal agreed with defendant in part. A sentencing enhancement for a prior prison term required, among other things, that the prior prison term be based on a felony conviction. "But that was not true of the prior prison term here." The Court found that although defendant served this prison term after being convicted of a felony, that felony conviction was reduced to a misdemeanor under Proposition 47 (the Safe Neighborhoods and Schools Act) before sentencing in this case. The trial court thus had no ground for increasing defendant’s sentence based on his serving this prior prison term. Judgment was modified to address this error, and judgment was affirmed as modified.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.