People v. Alatriste CA2/2
B338283
Cal. Ct. App.Mar 21, 2025Background
- Jose Alatriste was convicted at age 18 of second degree murder and other felonies related to a gang shooting, resulting in a sentence of 77 years to life in prison.
- Alatriste petitioned for resentencing under Penal Code § 1170(d), arguing his sentence was the functional equivalent of life without parole (LWOP), as later interpreted by case law.
- The trial court denied his petition, holding that Alatriste was ineligible because he was not expressly sentenced to LWOP and because he was entitled to a parole hearing under § 3051 after 25 years.
- On appeal, both Alatriste and the prosecution agreed that his sentence was functionally equivalent to LWOP and that the trial court erred by not considering this.
- The Court of Appeal reverses, concluding precedent requires juveniles sentenced to the functional equivalent of LWOP to be eligible to seek resentencing under § 1170(d), and the availability of § 3051 parole does not foreclose relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is § 1170(d) relief limited to explicit LWOP sentences? | Yes, only explicit LWOP sentences qualify. | No, functional LWOP sentences qualify. | Court: Functional LWOP sentences qualify for § 1170(d) relief. |
| Is Alatriste’s 77-to-life sentence functionally equivalent to LWOP? | Yes, it meets the definition established by case law. | No, the sentence is not long enough. | Court: 77 to life is functionally equivalent to LWOP. |
| Does eligibility for § 3051 parole bar resentencing under § 1170(d)? | Yes, § 3051 provides adequate relief. | No, § 1170(d) still applies. | Court: § 3051 parole eligibility does not bar § 1170(d) relief. |
| Was denying the resentencing petition error? | No error; ineligible under law. | Yes, error to deny on these grounds. | Court: Error to deny; order reversed and remanded. |
Key Cases Cited
- People v. Contreras, 4 Cal.5th 349 (Cal. 2018) (held a 50-to-life sentence for a juvenile is functionally equivalent to LWOP)
- People v. Franklin, 63 Cal.4th 261 (Cal. 2016) (section 3051 provides parole hearings but does not bar resentencing relief)