People v. White CA4/1

California Court of Appeal Mar 11, 2025 No. D082503Unpublished

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Holding. The court held that text messages between a defendant and prostitutes were admissible as operative facts and under the party statement and coconspirator hearsay exceptions, rendering the expert's reliance on them proper.

Issues

Whether text messages between a defendant and prostitutes constitute inadmissible hearsay.
Whether an expert witness improperly relied on the truth of hearsay statements in forming an opinion.
Whether the coconspirator hearsay exception applies to minor victims who are immune from prosecution.

Disposition. Affirmed

Quotations verified verbatim against the opinion

“A prostitute’s statements may be admitted as operative facts to prove pimping and pandering charges.”

“In addition to being operative facts, the text messages were also admissible under statutory hearsay exceptions.”

“Immunity for prostitutes or human trafficking victims “does not preclude treating them as uncharged coconspirators for purposes of the coconspirator exception to the hearsay rule.””

Filed 3/11/25 P. v. White CA4/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

COURT OF APPEAL, FOURTH APPELLATE DISTRICT

DIVISION ONE

STATE OF CALIFORNIA

THE PEOPLE, D082503

Plaintiff and Respondent,

v. (Super. Ct. No. SCD293806)

COLUMBUS WHITE,

Defendant and Appellant.

APPEAL from a judgment of the Superior Court of San Diego County, Aaron H. Katz, Judge. Affirmed. Johanna Pirko, under appointment by the Court of Appeal, for Defendant and Appellant. Rob Bonta, Attorney General, Lance E. Winters, Chief Assistant Attorney General, Charles C. Ragland, Assistant Attorney General, Melissa Mandel and Seth M. Friedman, Deputy Attorneys General, for Plaintiff and Respondent.

I. INTRODUCTION

Columbus White appeals from his convictions for human trafficking, pimping, and pandering. White claims that text messages between the

prostitutes and him were inadmissible hearsay, and the People’s expert improperly relied on the truth of those texts. Finding the texts admissible under hearsay exceptions, we disagree and affirm the conviction.

II. BACKGROUND

In 2023, the Office of the San Diego District Attorney charged White with human trafficking, pimping, and pandering of minor Maria S. between January 23, 2022, and January 31, 2022 (Pen. Code, §§ 236.1, subd. (c)(1), 266h, subds. (a) & (b)(1), 266i, subds. (a)(1) & (b)(1); counts 1–3); pimping and pandering of Gabriella J. between January 8, 2022, and February 21, 2022 (id., §§ 266h, subd. (a), 266i, subd. (a)(1); counts 4–5); pimping and pandering of Juanica L. between February 2, 2022, and February 22, 2022 (id., §§ 266h, subd. (a), 266i, subd. (a)(1); counts 6–7); and pimping and pandering of Marketta G. between February 17, 2022, and February 21, 2022 (id., §§ 266h, subd. (a), 266i, subd. (a)(1); counts 8–9). At White’s trial, the trial court admitted text messages between White

People v. White CA4/1

AI Brief

COURT OF APPEAL, FOURTH APPELLATE DISTRICT

DIVISION ONE

STATE OF CALIFORNIA

THE PEOPLE, D082503

COLUMBUS WHITE,

I. INTRODUCTION

II. BACKGROUND

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III. DISCUSSION

IV. DISPOSITION

RUBIN, J.

KELETY, J.

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