People v. Quarterman – Case Brief Summary (California)

In People v. Quarterman (2012) 202 Cal.App.4th 1280, the defendant pawned a camera while allegedly knowing it was stolen. (Id. at p. 1284.)

The preliminary hearing and the probation violation hearing were held at the same time with a single police officer as the only witness. (Id. at pp. 1284-1285.) The trial court held the defendant to answer on the criminal charges but found the probation violation allegation untrue. (Id. at p. 1285.)

Over the defendant's objections, the People filed a new probation violation petition before a different judge, making the same allegation as in the first petition. (Quarterman, supra, 202 Cal.App.4th at p. 1285.) The People presented testimony from the pawnshop manager and the camera's owner. (Ibid.) The petition was sustained this time. (Ibid.)

The Court of Appeal found the first probation violation barred the second probation revocation proceeding. It found the first and second revocation proceedings involved the same issues, " 'whether the defendant's conduct demonstrates that the leniency extended by the grant of probation remains justified.' " (Quarterman, supra, 202 Cal.App.4th at p. 1289.)

The People had the opportunity to present their entire case at the first probation hearing, and the issue sought to be relitigated was necessarily decided at the first revocation hearing. (Id. at pp. 1289-1290.) The first decision was final, and the parties were the same at both hearings. (Id. at pp. 1290-1291.) Since the requirements for collateral estoppel were met, the Court of Appeal concluded that the doctrine precluded relitigating the issue decided in the first revocation hearing. (Id. at pp. 1291, 1298.)