People v. Jones CA2/1
B334961
Cal. Ct. App.Mar 20, 2025Background
- In 1990, Ronald Lee Jones was convicted of first-degree murder and robbery, with jury findings that he personally used a firearm and a special circumstance that the murder occurred during a robbery.
- The jury instructions at trial permitted conviction for felony murder without requiring intent to kill or direct action in the killing, consistent with law at that time.
- In 2018, the Legislature amended California's felony-murder rule (Penal Code § 189) via Senate Bill 1437, limiting murder liability to actual killers, aiders or abettors with intent to kill who assist in the murder, or major participants acting with reckless indifference.
- Jones filed a petition for resentencing under the new law, claiming ineligibility for murder conviction under current standards.
- The superior court denied the petition at the prima facie stage, finding the record conclusively showed Jones was convicted under a theory still valid after the law change.
- On appeal, the issue was whether the record conclusively established Jones as the actual killer or as someone who aided in the killing (not just the robbery).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the record conclusively establishes Jones as the actual killer or someone who aided in the killing (not just robbery) | Jones is the sole perpetrator, instructions and arguments only presented him as actual killer; special circumstance and firearm use findings confirm | The jury was permitted to convict under felony murder without finding he was actual killer or aided in killing; could have aided only in robbery | Record does not conclusively establish Jones as the actual killer or direct aider in the killing; insufficient to deny petition at prima facie stage |
| Whether the jury's special circumstance and personal firearm use findings suffice under current Penal Code § 189(e)(2) | Special circumstance required jury to find Jones was actual killer or intended to kill; personal firearm use further supports this | Special circumstance finding could rest solely on intent to kill, not on act of aiding the killing; use of firearm does not require it was fired or used to kill | Special circumstance and firearm use findings do not establish aiding in the murder; act requirement under § 189(e)(2) not met by intent alone |
| Correct interpretation of Penal Code § 189(e)(2) post-SB 1437 (actus reus requirement) | Only intent to kill and participation in underlying felony sufficient for felony murder liability | § 189(e)(2) requires both intent to kill and aiding/assisting in the killing itself, not just the felony | Court holds that aiding or assisting in the killing is required; mere intent to kill and aiding robbery is insufficient |
| Whether denial of resentencing petition at prima facie stage was permissible | Record conclusively shows ineligibility for relief, so denial at prima facie stage was justified | Record does not preclude potential eligibility; factual questions remain | Denial was error; case remanded for evidentiary hearing |
Key Cases Cited
- People v. Lewis, 11 Cal.5th 952 (Cal. 2021) (sets procedure and prima facie standards for resentencing under SB 1437)
- People v. Curiel, 15 Cal.5th 433 (Cal. 2023) (prima facie stage requires the record to conclusively negate petitioner’s eligibility)
- People v. Jones, 30 Cal.4th 1084 (Cal. 2003) (personal use of a firearm does not require proof that the firearm was discharged)
- Lungren v. Deukmejian, 45 Cal.3d 727 (Cal. 1988) (plain language controls statutory interpretation)