P. v. Snowden
Following a bench trial, the trial court convicted defendant Daniel Louis Snowden of two counts of forcible rape (Pen. Code, 261, subd. (a)(2)),[1]kidnapping to commit rape ( 209, subd. (b)(1)), false imprisonment ( 236), and assault with a deadly weapon ( 245, subd. (a)(1)), while sustaining firearm and one one-strike allegations ( 667.61, subds. (d)(2), (e)(4), (e)(5), 12022.5, subd. (a), 12022.53, subd. (b)). Defendant was sentenced to a prison term of 50 years to life plus 13 years. On appeal, defendant contends: (1) his jury trial waiver was invalid; (2) insufficient evidence supports his false imprisonment conviction; (3) the false imprisonment conviction must be reversed as a lesser included offense of forcible rape; (4) the court did not understand its discretion to impose concurrent life terms; and (5) his life term for kidnapping to commit rape was unauthorized. Court shall order a correction to the abstract and affirm.



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