People v. Argeta
210 Cal. App. 4th 1478
Cal. Ct. App.2012Background
- Defendants Cristian Argeta and Camilo Hernandez were convicted by jury of one count of murder and five counts of attempted murder.
- Hernandez was 15 years old at the time of the crimes and was convicted as an aider and abettor; Argeta was 18 and a principal in murder.
- The trial court imposed long aggregate sentences, including a minimum of 100 years for Hernandez and a lengthy sentence for Argeta with presentence credit.
- The matter was initially submitted, then briefed anew after Caballero and Miller; the court analyzed juvenile sentencing under Graham, Miller, and Caballero.
- The court affirmed Argeta’s sentence with an adjustment to presentence credit and reversed Hernandez’s sentence for resentencing consistent with Miller and Caballero.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Hernandez's juvenile status makes his sentence unconstitutional | Hernandez's sentence is the functional equivalent of life without parole. | The sentence complies with Graham, Miller, and Caballero. | Hernandez’s sentence reversed; remanded for resentencing |
| Whether Argeta's sentence is cruel or unusual under Graham, Miller, and Caballero | Argeta's age falls near adulthood; penalties should follow juvenile standards. | Argeta’s sentence is permissible; not categorically cruel or unusual. | Argeta's sentence affirmed; no categorical invalidity |
| Whether remand is required to reconsider Hernandez's sentence in light of Miller and Caballero | The sentencing scheme must reflect age-specific considerations. | Existing framework suffices without automatic disruption. | Remanded for reconsideration of Hernandez’s sentence consistent with Miller and Caballero |
Key Cases Cited
- Graham v. Florida, 560 U.S. 48 (2010) (juvenile life-without-parole for nonhomicide offenses violates Eighth Amendment)
- Miller v. Alabama, 132 S. Ct. 2455 (2012) (mandatory life-without-parole for juveniles in homicide cases unconstitutional)
- People v. Caballero, 55 Cal.4th 262 (2012) (juvenile sentence to minimum terms exceeding life expectancy violates Graham; requires parole considerations)
- People v. Mendez, 188 Cal.App.4th 47 (2010) (juvenile sentencing considerations and rehabilitation implications)