People v. Arias
240 Cal. App. 4th 161
| Cal. Ct. App. | 2015Background
- Barney Arias pleaded guilty (1996) to heroin offenses and admitted two prior strikes: an adult robbery conviction and a juvenile adjudication for murder; sentenced to 26 years-to-life.
- Arias petitioned under Penal Code §1170.126 (Prop. 36) to recall his indeterminate life term and be resentenced as a second-strike offender.
- The People opposed, arguing Arias’s juvenile murder adjudication counts as a prior conviction that disqualifies him from resentencing under §1170.126(e)(3).
- Arias argued Welfare & Institutions Code §203 prevents juvenile adjudications from being treated as convictions “for any purpose,” so his juvenile adjudication cannot bar resentencing eligibility.
- The trial court denied the petition; the Court of Appeal affirmed, holding a juvenile adjudication that qualifies as a strike under §§667(d)(3)/1170.12(b)(3) also counts as a prior conviction for §1170.126(e) eligibility.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a juvenile adjudication that was treated as a strike prior under the three strikes law counts as a “prior conviction” for §1170.126(e) resentencing eligibility | The juvenile adjudication qualifies as a prior conviction for §1170.126(e)(3) and disqualifies Arias from resentencing | Welf. & Inst. Code §203 forbids treating juvenile wardship adjudications as convictions “for any purpose,” so it cannot bar §1170.126 relief | A juvenile adjudication that may be deemed a strike under §§667(d)(3)/1170.12(b)(3) also constitutes a prior conviction for §1170.126(e); Arias is ineligible |
Key Cases Cited
- People v. Yearwood, 213 Cal.App.4th 161 (Cal. Ct. App. 2013) (interpreting Prop. 36 and §1170.126 resentencing framework)
- In re Greg F., 55 Cal.4th 393 (Cal. 2012) (three strikes provisions prevail over contrary law)
- People v. Fowler, 72 Cal.App.4th 581 (Cal. Ct. App. 1999) (juvenile adjudications may be used as strikes though not transformed into criminal convictions)
- People v. Osuna, 225 Cal.App.4th 1020 (Cal. Ct. App. 2014) (statutory construction principles in interpreting §1170.126)
- People v. Pacheco, 194 Cal.App.4th 343 (Cal. Ct. App. 2011) (juvenile adjudication can serve as strike despite §203)