People v. Lewis CA4/2, E082171

Loran L. Lewis was originally charged with two counts of murder, evading police, and two counts of unlawful vehicle taking after a 1999 car theft led to a fatal crash.
He and a co-defendant were convicted of second-degree felony murder and related counts; this conviction was reversed after a change in California law regarding what qualifies as an inherently dangerous felony.
Lewis later pled guilty to two counts of voluntary manslaughter in 2010 as part of a negotiated plea and was sentenced to three years, consecutive to his earlier sentence on vehicle theft counts.
In 2022, Lewis filed a petition for resentencing under Penal Code section 1172.6, as amended to allow relief for those who pled guilty to manslaughter under theories of murder since narrowed by law.
The trial court denied his petition at the prima facie stage, reasoning that he had already served his manslaughter sentence and was thus ineligible for relief.
The People conceded on appeal that the trial court erred by denying Lewis an evidentiary hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Eligibility for 1172.6 relief after serving sentence on manslaughter	Defendant is ineligible because sentence already served	Eligibility not affected by having served time; conviction can still be vacated	Court agrees with defendant; prior completion of sentence does not moot eligibility
Requirement for evidentiary hearing at prima facie stage	Defendant is not entitled to a hearing since not eligible for relief	Making prima facie showing entitles petitioner to an evidentiary hearing	Defendant made a prima facie showing; summary denial was in error; hearing required
Effect of plea to manslaughter on eligibility	Plea and factual basis foreclose relief	Admission in plea did not establish a disqualifying theory of murder liability	Plea did not establish ineligibility at prima facie stage; factual basis insufficient
Resentencing mechanics under 1172.6	No relief, as defendant’s sentence was already complete	Relief includes vacatur of conviction, even if sentence completed	Statutory language supports vacatur regardless of sentence served if underlying conviction is covered

People v. Lewis, 11 Cal.5th 952 (Cal. 2021) (sets forth standards for 1172.6 resentencing eligibility and hearings)
People v. Howard, 34 Cal.4th 1129 (Cal. 2005) (ruled certain felonies not inherently dangerous for felony-murder rule)
People v. Arias, 45 Cal.4th 169 (Cal. 2008) (addresses statutory interpretation methods)