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Oct 30, 2010
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/or private property as a matter of fundamental constitutional law…. The Constitution is a document of independent force, *1226 creating rights in persons. There are few, if any, statutory procedures which are constitutionally required for the acquisition of rights or for their protection.” (Id. at p. 607, 89 S.Ct. 733.)
The basic right to perfect an appeal, as determined by Crudup, is a property right derived from the Constitution. (See Baker v. Superior Court (1981) 122 Cal.App.3d 92, 96, 175 Cal.Rptr. 848 [right to perfect appeal is derived from the Fourteenth Amendment to the Constitution].) We, therefore, turn to the issue whether the federal or state Constitution affords greater protection of that right than the California Constitution. Because we conclude that it does not, we need not address the subsidiary issues whether the Constitution of the United States confers more rights than the California Constitution, whether a constitutional right to perfect an appeal existed at common law, and whether Proposition 8 impairs a right or remedy provided in the Constitution of the United States.
III
The purpose of the right to perfect an appeal is to ensure that the judgment of an inferior court is final and is not open to reconsideration in a higher court. (People v. Karaman (1992) 4 Cal.4th 335, 369, 14 Cal.Rptr.2d 801, 842 P.2d 101 [right to appeal ensures finality of judgment].) Because of the nature of a direct appeal, “the party whose judgment is appealed from may take into account as legal aid to his defense any consideration which he had a right to expect from the court below.” (Id. at p. 369, 14 Cal.Rptr.2d 801, 842 P.2d 101.) In a criminal case, this means that the “appellant has a right to expect his attorney to represent him adequately during any appeal, through the appellate courts to the [United States] Supreme Court and then back to the state’s highest court.” (Id. at p. 368, 14 Cal.Rptr.2d 801, 842 P.2d 101, fn. omitted.) The constitutional right to perfect an appeal is rooted in the basic right to due process of law, which is
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