Jewerelene Steen, Petitioner v. Appellate Division, Superior Court of Los Angeles County, Respondent; the People…

Summary

The court upheld the misdemeanor complaint generated and filed electronically by a superior court clerk after concluding that the governing statute, properly construed, requires prosecutorial approval and therefore does not authorize a judicial employee to initiate a prosecution independently. It further held that prosecutorial approval may be given implicitly in advance through an established practice, that due process does not require individualized prosecutorial screening of each qualifying complaint, and that the complaint timely commenced the prosecution. The petition for writ of mandate was denied. Justice Liu, concurring, would have found the existing automated process inconsistent with separation of powers absent transparent, contemporaneous prosecutorial approval, although he agreed with the judgment.