P. v. Rodriguez CA1/4
Largely on the strength of testimony offered by two experts, a jury found Guillermo Rodriguez to be a sexually violent predator (SVP) within the meaning of the Sexually Violent Predators Act (SVPA) (Welf. & Inst. Code, § 6600 et seq.) and the trial court committed him to the Department of State Hospitals (DSH) for an indeterminate term.
Shortly after the conclusion of briefing in this matter, the California Supreme Court decided People v. Sanchez (2016) 63 Cal.4th 665 (Sanchez), which substantially limited the admissibility of case-specific expert testimony. We requested, and received, supplemental briefing addressing the impact of Sanchez on this appeal. We conclude that, under Sanchez, the expert witnesses in this case improperly testified to case-specific hearsay that was not independently proved by competent evidence or covered by a hearsay exception. Because this evidentiary error was prejudicial, we reverse.
Comments on P. v. Rodriguez CA1/4