People v. Farley CA4/1
D083515
Cal. Ct. App.Apr 14, 2025Background
- In 2010, Craig Farley and Pierre Terry entered Jonathan Pleasant's apartment to commit a robbery and burglary; Pleasant was a known marijuana dealer.
- During the incident, Pleasant was shot and killed with a shotgun; Farley and Terry fled the scene.
- Farley was convicted of first-degree murder under California's felony murder rule, with a gang enhancement, and sentenced to life without parole, plus 25 years to life; the conviction was affirmed on direct appeal.
- Following changes to California's murder statutes (Senate Bill 1437), Farley petitioned for resentencing, claiming he could not be convicted of murder under the amended law, as he was not the shooter and lacked the requisite intent.
- The resentencing court found Farley still met the standards for felony murder as a major participant with reckless indifference to human life under the revised law; Farley appealed that decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Farley was a major participant in the felony acting with reckless indifference to life | Substantial evidence exists he planned, supplied weapons, and acted knowingly | Insufficient evidence supports major participation or reckless indifference | Substantial evidence supports finding Farley a major participant with reckless indifference |
| Whether Farley's age (21) at the time should reduce his culpability | No evidence links age to impulsivity or peer pressure | Youth must be considered under recent case law | Any error in failing to consider youth was harmless |
| Sufficiency of evidence for felony murder under amended law | Met burden under Banks/Clark factors | Record lacks sufficient evidence | Court found prosecution met its burden |
| Requirement to reach alternative arguments if felony murder conviction stands | Not necessary if felony murder upheld | Alternative arguments presented | Did not address, as primary issue was dispositive |
Key Cases Cited
- People v. Banks, 61 Cal.4th 788 (Cal. 2015) (enumerates factors for major participant analysis in felony murder)
- People v. Clark, 63 Cal.4th 522 (Cal. 2016) (clarifies "reckless indifference to human life" for felony murder liability)
- People v. Zamudio, 43 Cal.4th 327 (Cal. 2008) (standard for substantial evidence review)
- People v. Maury, 30 Cal.4th 342 (Cal. 2003) (circumstantial evidence and reasonable inferences standard)