A172132
Cal. Ct. App.Aug 25, 2025Background
- Nathan Medina was convicted in 2009 of first-degree murder, two counts of attempted premeditated murder, and first-degree burglary, receiving a sentence of 40 years plus 50 years to life in prison.
- The convictions stemmed from Medina's entry into Beverly Rhoads's home where he shot and killed Joshua Rhoads and attempted to kill Beverly Rhoads and another resident following a dispute involving a construction project.
- Medina's direct appeal of his conviction was previously affirmed by the court.
- In August 2024, Medina filed a petition for resentencing under Penal Code section 1172.6, citing changes to the law of murder made by Senate Bill No. 1437 (limiting vicarious liability for murder).
- The trial court denied Medina’s petition, finding he was the actual killer and thus ineligible for section 1172.6 resentencing relief.
- Medina appealed the denial, arguing trial error, bias, and the potential relevance of other recent ameliorative legislation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Eligibility for resentencing under § 1172.6 | Medina was the actual killer, ineligible for relief | Jury was instructed on felony murder, so verdict could be based on vicarious liability | Medina ineligible for resentencing; record showed he was actual killer |
| Consideration of unrelated ameliorative legislation | Not relevant to § 1172.6 eligibility | Recent legislation should support resentencing | Other statutes not applicable at the prima facie stage |
| Claims of trial error and judicial bias | Not raised; focus on statutory ineligibility | Supplemental brief alleges errors and bias | Claims not reviewable or unsupported, not properly before court |
| Factfinding at prima facie stage | Record establishes actual killer status | Court improperly engaged in factfinding | No improper factfinding; decision based solely on record |
Key Cases Cited
- People v. Hin, 17 Cal.5th 401 (Cal. 2025) (Senate Bill No. 1437 limited vicarious liability for murder)
- People v. Antonelli, 17 Cal.5th 719 (Cal. 2025) (procedure under section 1172.6 for resentencing those convicted under prior law)
- People v. Strong, 13 Cal.5th 698 (Cal. 2022) (resentencing under § 1172.6 unavailable for actual killer)
- People v. Lewis, 11 Cal.5th 952 (Cal. 2021) (assessing prejudice and harmless error in § 1172.6 context)