People v. Jones-Carnes CA3
C101116
Cal. Ct. App.May 20, 2025Background
- Davonntay Jones-Carnes was convicted for shooting and paralyzing Anthony D. in a grocery store parking lot after a dispute in 2018, with convictions including attempted murder and firearm enhancements.
- The jury found Jones-Carnes guilty of all charges, including gun and bodily injury enhancements; the trial court initially struck some enhancements but imposed lengthy sentences.
- The case was previously remanded to the trial court to clarify sentencing on certain enhancements and for the court to entertain any new sentencing objections Jones-Carnes might raise.
- At resentencing, Jones-Carnes sought relief based on youth, trauma, and progress, requested the court to strike or stay several enhancements, and moved for a continuance to investigate a claim under the Racial Justice Act.
- The court denied the continuance, imposed sentences for the attempted murder and enhancements, but did not clearly stay all enhancements as required; both Jones-Carnes and the People appealed aspects of the resentencing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Continuance for Racial Justice Act | Continuance unwarranted, Act claim waived | Needed continuance to investigate new claim | Denial of continuance was proper; Act claim was untimely |
| Imposition of Firearm Enhancement | Resentencing court properly imposed term | Court may have erred or abused discretion | Enhancement properly imposed; no abuse of discretion |
| Striking Enhancements under § 1385 | Court exercised discretion appropriately | Court failed to consider mitigating circumstances | Court considered factors; decision not arbitrary or capricious |
| Application of Section 654 | Court properly exercised discretion | Court didn't give weight to mitigating evidence | No abuse of discretion; court's reasoning upheld |
| Staying § 12022.5 Enhancement | Remand required for clarity | Enhancement improperly imposed | Judgment modified to stay enhancement, per prior directions |
Key Cases Cited
- People v. Hargis, 33 Cal.App.5th 199 (trial court's jurisdiction after remittitur is limited to appellate directions)
- People v. Carmony, 33 Cal.4th 367 (abuse of discretion standard in sentencing)
- People v. Buycks, 5 Cal.5th 857 (resentencing court's discretion to consider new facts and circumstances)
- People v. Scott, 9 Cal.4th 331 (waiver of sentencing errors not raised at sentencing)
- People v. Alvarez, 14 Cal.4th 968 (sentencing discretion and consideration of sentencing objectives)