Steen v. Appellate Div., Superior CourtAnnotate this Case
Petitioner was charged in a misdemeanor complaint electronically generated by a superior court clerk with willfully violating her written promise to appear. Petitioner pled no contest to the conviction. Petitioner subsequently challenged the conviction, contending that the complaint was void because it was not issued by an executive branch officer with prosecutorial authority in violation of the California Constitution’s separation of powers and due process clauses. The Supreme Court denied Petitioner’s petition for writ of mandate, holding the because the relevant prosecutorial agency has, through an established practice, implicitly approved in advance the clerk’s routine issuance of complaints for the offense of failure to appear, the practice is constitutional, and therefore, the complaint in this case is valid.