People v. Muhammad

Opinion

EPSTEIN, J.

It is a general rule that, outside of a contempt proceeding, trial courts lack inherent power to impose a monetary sanction against an attorney for misconduct in court. The authority to impose such a sanction must be found in a statute. This has been the declared law in California for at least the past 25 years. (See Bauguess v. Paine (1978) 22 Cal.3d 626 [150 Cal.Rptr. 461, 586 P.2d 942].) We apply it here in the context of a monetary fine levied against a prosecutor for exercising jury peremptory challenges in violation of the constitutional principles laid down in People…