Can a witness be impeached with any prior conduct involving moral turpitude?

"A witness may be impeached with any prior conduct involving moral turpitude whether or not it resulted in a felony conviction, subject to the trial court's exercise of discretion under Evidence Code section 352." (People v. Clark (2011) 52 Cal.4th 856, 931, fn. omitted.) "Because the court's discretion to admit or exclude impeachment evidence 'is as broad as necessary to deal with the great variety of factual situations in which the issue arises' [citation], a reviewing court ordinarily will uphold the trial court's exercise of discretion. [Citations.]" (Id. at p. 932.)

Evidence Code section 1202 provides, in pertinent part, "Evidence of a statement or other conduct by a declarant that is inconsistent with a statement by such declarant received in evidence as hearsay evidence is not inadmissible for the purpose of attacking the credibility of the declarant though he is not given and has not had an opportunity to explain or to deny such inconsistent statement or other conduct. Any other evidence offered to attack or support the credibility of the declarant is admissible if it would have been admissible had the declarant been a witness at the hearing." (Italics added.) "'Section 1202 creates "a uniform rule permitting a hearsay declarant to be impeached by inconsistent statements in all cases, whether or not the declarant has been given an opportunity to explain or deny the inconsistency." [Citation.] [] The purpose of section 1202 is to assure fairness to the party against whom hearsay evidence is admitted without an opportunity for cross-examination.' [Citation.]" (People v. Curl (2009) 46 Cal.4th 339, 361.)

Defendant concedes receiving stolen property and robbery involve acts of moral turpitude suggesting "a willingness to lie." (See People v. Wheeler (1992) 4 Cal.4th 284, 295-296.) She objects, however, because her pending cases had not yet resulted in felony convictions, and she cites and discusses several cases in her favor. However, these cases predate the passage of Proposition 8. After Proposition 8, a felony

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conviction is no longer required for impeachment evidence. (People v. Wheeler, supra, 4 Cal.4th at pp. 291-294.)