People v. Caddell CA4/1
D085600
Cal. Ct. App.Jul 2, 2025Background
- Cayson Lamont Caddell was convicted at age 16 for first-degree murder, attempted murder, and participation in a criminal street gang for offenses committed in 2006.
- The jury found true certain firearm enhancements related to these charges.
- Caddell was sentenced in 2010 to a prison term of 40 years, plus 80 years to life (an aggregate of 120 years).
- In 2023, Caddell petitioned for resentencing under Penal Code section 1170(d)(1), which allows certain juvenile offenders sentenced to life without parole (LWOP) to seek recall and resentencing.
- The trial court denied the petition, finding that Caddell was not serving the functional equivalent of an LWOP sentence due to potential parole eligibility under section 3051.
- On appeal, the State conceded error, agreeing with Caddell's argument about the functional equivalence of his sentence to LWOP.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Eligibility for section 1170(d)(1) relief | Caddell's sentence is functionally LWOP, making him eligible for relief | Parole eligibility under section 3051 means sentence is not LWOP | Caddell is eligible for section 1170(d)(1) relief because his sentence is functionally LWOP |
| Effect of youth offender parole eligibility | Youth offender parole eligibility does not affect eligibility for relief | Youth parole eligibility negates need for relief | Youth parole eligibility under section 3051 does not preclude finding of de facto LWOP and does not preclude relief |
| Equal protection claim | Excluding functional LWOP sentences from relief violates equal protection | Not addressed separately | Constitutional right to equal protection requires including functional LWOP sentences for relief |
| Application of precedent from Ortega | Division Three's contrary ruling in Ortega is unpersuasive | Relies on Heard and rejects Ortega | Follows Heard and not Ortega, thus granting relief |
Key Cases Cited
- People v. Caballero, 55 Cal.4th 262 (Cal. 2012) (holding that de facto LWOP sentences for juveniles are unconstitutional)
- People v. Franklin, 63 Cal.4th 261 (Cal. 2016) (discussing youth offender parole hearings)