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

Summary

The court denied writ relief, holding that Penal Code section 959.1(c) permits a court clerk to electronically generate specified misdemeanor complaints only with the approval of the responsible prosecutor. The prosecutor's established practice of implicitly approving such complaints validly authorized petitioner's complaint, and due process did not require individualized prosecutorial review before filing. Because the complaint was valid when filed within one year of the offense, it timely commenced the prosecution. Justice Liu, concurring, agreed with the due process analysis but would have found the automated clerk-generated charging process inconsistent with separation of powers absent transparent, express prosecutorial approval.