California v. Miranda
Annotate this CaseDefendant-appellant Michael Miranda was convicted on 13 counts charging sex crimes against two minor girls, including oral copulation of an unconscious person, rape of an unconscious person, and sexual penetration of an unconscious person. He was sentenced under the One Strike law. On appeal, he contended in part that the jury should have been instructed on lesser included offenses, and that his ineligibility for youth offender parole hearings violated equal protection. The Court of Appeal agreed that battery was a lesser included offense of oral copulation of an unconscious person, rape of an unconscious person, and sexual penetration of an unconscious person. Given that battery required only an offensive touching, it was impossible to commit any of these crimes without also committing battery against that person. Because of the evidence presented, the Court concluded the trial court was required to instruct the jury on battery as a lesser included offense as to one of Miranda’s crimes, oral copulation of an unconscious person. Therefore, that conviction was reversed and the sentence vacated, as there was a reasonable probability that, absent the error, the jury would have convicted him of only battery if instructed as to that option. As to Miranda’s other two crimes, the Court found the notion that Miranda committed battery but not the greater crimes lacked a grounding in the evidence, so the trial court had no duty to instruct on battery as a lesser included offense. In addition, the Court rejected Miranda’s other challenges to his convictions, including his equal protection challenge.
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