People v. Ugaldemedina CA4/3

Filed 1/16/26 P. v. Ugaldemedina CA4/3

NOT TO BE PUBLISHED IN OFFICIAL REPORTS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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FOURTH APPELLATE DISTRICT

DIVISION THREE

THE PEOPLE,

Plaintiff and Respondent, G063385

v. (Super. Ct. No. 23NF1437)

ANGEL UGALDEMEDINA, OPINION

Defendant and Appellant.

Appeal from a judgment of the Superior Court of Orange County, Richard M. King, Judge. Reversed and remanded. Susan S. Bauguess, 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, Eric A.

Swenson and Monique Myers, Deputy Attorneys General, for Plaintiff and Respondent. * * * Angel Ugaldemedina appeals his 2023 convictions for domestic violence battery, false imprisonment, second degree robbery, and a prior serious felony and strike offense. Prior to the start of his jury trial, Ugaldemedina sought to have all charges dismissed on the basis that the prosecution destroyed exculpatory surveillance footage. The trial court denied the request. Ugaldemedina contends this was error. But because the surveillance video was never in the possession of the prosecution, we agree with the trial court. Ugaldemedina also argues the trial court improperly admitted evidence of his past acts of domestic violence. However, the bases he sets forth do not support his position. The admissions did not improperly lower the prosecution’s burden of proof nor permit the jury to make unlawful inferences. Last, Ugaldemedina contends the jury’s true finding that he suffered a prior serious felony and strike offense based on a past gang related conviction was error. With this contention, we agree. In 2021, the Legislature amended Penal Code1 section 186.22 with the passage of Assembly Bill No. 333 (2021–2022 Reg. Sess.) (Assembly Bill 333). In many respects, it changed the elements of a section 186.22 offense (People v. Fletcher (2025) 18 Cal.5th 576, 582 (Fletcher), which the prosecution here did not prove. After Ugaldemedina’s conviction and while his appeal was pending, the