People v. Champagne CA4/1
Filed 1/21/26 P. v. Champagne CA4/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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, D084663
Plaintiff and Respondent,
v. (Super. Ct. No. FMB23000430)
MICHAEL DAVID CHAMPAGNE,
Defendant and Appellant.
APPEAL from a judgment of the Superior Court of San Bernardino County, Sarah Oliver, Judge. Affirmed. Jason Szydlik, 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 Heather M. Clark, Deputy Attorneys General, for Plaintiff and Respondent. Michael David Champagne appeals from his conviction on five felony offenses, contending (1) the trial court violated his Fourteenth Amendment right to due process by misinforming him of the minimum probation term
available, (2) trial counsel provided ineffective assistance of counsel by failing to inform the trial court of the correct minimum probation term, and (3) the cumulative impact of the errors rendered the proceeding fundamentally unfair. The People concede the trial court erred when advising on the minimum probation term. Even so, we conclude it did not rise to the level of a federal constitutional error, and we perceive no prejudice from the misadvisement. Champagne’s ineffective assistance of counsel claim relies on—and thus fails for—the same prejudice argument. And we conclude the cumulative effect of these claimed errors does not require reversal. We therefore affirm. I. In November 2023, Champagne subjected his wife to hours of physical and mental abuse in their shared residence. Based on these events, the People charged Champagne with assault with a deadly weapon (Pen. Code, § 245, subd. (a)(1); count 1); assault by means of force likely to produce great bodily injury (§ 245(a)(4); count 2); criminal threats (§ 422(a); count 3); injuring a spouse (§ 273.5(a); count 4); and false imprisonment by violence (§ 236; count 5). At a pretrial hearing, the court noted the parties had not come to an agreement on a plea bargain, despite “some attempts,” and they were set to go to trial the next day. The court informed Champagne the maximum prison time for the charged offenses was seven years and four months in state prison. The court also acknowledged the People’s “current [plea bargain] offer . . . is [four] years of probation with 180 days in the county jail.” With custody credits and the work-release program, the court informed Champagne that, under this offer, he would “be released today” and needed to serve about 16 more days “on the weekend work-release program.”
More from California Court of Appeal
- People v. Hill (1998)
- In Re Autumn H. (1994)
- Nwosu v. Uba (2004)
- In Re Casey D. (1999)
- Santisas v. Goodin (1998)
- Cahill v. San Diego Gas & Electric Co. (2011)
- People v. Rivera (2015)
- People v. Barnett (1998)
- People v. Serrano (2012)
- Benach v. County of Los Angeles (2007)