When will a court bar a witness from giving evidence of moral turpitude in a criminal case?

When exercising discretion under Evidence Code section 352 to bar impeachment with prior conduct, trial courts should "be guidedbut not boundby the factors set forth in People v. Beagle (1972) 6 Cal.3d 441, and its progeny. [Citations.] When the witness subject to impeachment is not the defendant, those factors prominently include whether the [conduct] (1) reflects on honesty and (2) is near in time. [Citation.]" (People v. Clair (1992) 2 Cal.4th 629, 654.) In addition, it is reasonable for a trial court to consider the witness's age at the time of the prior conduct. (Cf. People v. Burns (1987) 189 Cal.App.3d 734, 738.) "The rule is settled that the trial court's discretion to exclude or admit relevant evidence under Evidence Code section 352 'is as broad as necessary to deal with the great variety of factual situations in which the issue arises, and in most instances the appellate courts will uphold its exercise whether the [prior conduct evidence] is admitted or excluded.' [Citation.]" (People v. Kwolek (1995) 40 Cal.App.4th 1521, 1532.) The trial court's ruling " 'must not be disturbed on appeal except on a showing that the court exercised its discretion in an arbitrary, capricious or patently absurd manner that resulted in a manifest miscarriage of justice. [Citations.]' [Citation.]" (People v. Rodrigues (1994) 8 Cal.4th 1060, 1124-1125.)

In this case, neither party cited to the trial court or to this court any authority to support defendant's claim that the misdemeanor offense under section 626.10 of bringing a weapon onto school grounds is one involving moral turpitude, and we have found no such authority. Although possession of a concealed handgun is a crime involving moral turpitude (People v. Robinson (2005) 37 Cal.4th 592, 626), an offense under section 626.10 would not involve a handgun.⁶ There is no dispute that petty theft is a

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