California v. Martin
Annotate this CaseThe Court of Appeal held in California v. Schaffer, 53 Cal.App.5th 500 (2020) that a parolee exposed to a 180-day jail term for a parole violation resulting from non-criminal conduct was not entitled, under United States v. Haymond, 139 S.Ct. 2369 (2019), to have a jury determine beyond a reasonable doubt whether he had violated his parole. Defendant and appellant Tyrel Martin was convicted in 2014 of committing a lewd and lascivious act with a child by use of force, violence, duress, menace, or fear, for which he was sentenced to a 5-year prison term. He was released on parole in 2018. In August 2019, the Division of Adult Parole Operations of the California Department of Corrections and Rehabilitation (DAPO) petitioned to revoke Martin’s parole, alleging that he failed to report to his parole agent upon release from custody, that he failed to register as a sex offender, and that he did not participate in electronic monitoring. As part of a compromise with the DAPO, Martin admitted the allegations regarding failure to report and failure to participate in electronic monitoring, and he was ordered to serve a 180-day jail term with credit for time served. A month later, the trial court set aside Martin’s admissions, vacated the sentence, and set a formal revocation hearing, having been notified that the case should have been governed by Penal Code section 3000.08 (h), providing that, for certain parolees, a parole violation meant that the parolee will be sent back to prison, with the Board of Parole Hearings responsible for determining future parole consideration. Following a contested revocation hearing, the trial court found that Martin violated parole by failing to report to his parole agent upon release from custody. Martin was ordered to return to prison. Martin contends on appeal, as he did in trial court, that the United States Supreme Court’s decision in Haymond entitled him to have a jury determine whether he violated parole beyond a reasonable doubt. The Court of Appeal concluded Martin was not entitled to have a jury make findings using the beyond a reasonable doubt standard under Haymond, despite the possibility he faced a lengthy prison sentence for his parole violation.
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