People v. Yartz

Summary

The Supreme Court of California held that an SVPA civil commitment proceeding is a special proceeding of a civil nature, not a civil suit, under former Penal Code section 1016, subdivision (3). Accordingly, the defendant’s 1978 conviction based on a nolo contendere plea could be used as a predicate prior conviction in the SVPA proceeding. The court reversed the Court of Appeal’s judgment and remanded for further proceedings.

Holdings

1. An SVPA commitment proceeding is a special proceeding of a civil nature, not a civil action or civil suit, because it is neither an action at law nor a suit in equity and is commenced by petition independently of a pending action.
2. Former Penal Code section 1016, subdivision (3), did not preclude using Yartz's 1978 conviction based on a no contest plea as a predicate prior conviction supporting his SVPA commitment.
3. Evidence Code former section 1300 did not independently bar use of Yartz's 1978 conviction because its scope was coextensive with former Penal Code section 1016, subdivision (3).

Questions Presented

1. Whether an SVPA civil commitment proceeding is a "civil suit" within the meaning of former Penal Code section 1016, subdivision (3).
2. Whether former Penal Code section 1016, subdivision (3), barred use of Yartz's 1978 conviction based on a no contest plea as a predicate prior conviction in the SVPA proceeding.
3. Whether Evidence Code former section 1300 independently barred use of the 1978 conviction.

Disposition

reversed_and_remanded