People v. Meier CA4/1, D084099

Christopher Michael Meier was convicted in 2018 of two counts of first degree burglary and one misdemeanor count of resisting arrest, with prior convictions alleged.
The trial court imposed a 15 year 8 month sentence, and verbally declined to impose a one-year "prison prior" enhancement.
On appeal, the convictions were affirmed, but the case was remanded to consider eligibility for mental health diversion and for possible resentencing due to changes in the law affecting prison prior enhancements.
By April 2021, the trial court found Meier ineligible for diversion and resentenced him to the same term, including (in the abstract) the now-invalid prison prior enhancement.
Subsequent laws (Senate Bill 483, Penal Code § 1172.75) invalidated non-sex offense prison prior enhancements imposed before Jan. 1, 2020; Meier sought resentencing relief under this statute.
The trial court denied resentencing in 2024, finding Meier ineligible because his current sentence had been imposed after the relevant statutory date and corrected the record to strike the invalid enhancement.

Issue	Meier's Argument	People's Argument	Held
Eligibility for resentencing under § 1172.75	April 2021 resentencing does not bar eligibility; any sentence with a prison prior (imposed/stayed) qualifies	Only judgments with a prison prior imposed and executed before 2020 qualify	Meier is ineligible under § 1172.75; judgment imposed after Jan. 1, 2020 does not qualify
Effect of court's oral vs. abstract pronouncement	Abstract shows stayed enhancement, so should trigger resentencing	Only actual oral imposition counts; oral pronouncement controls	Oral pronouncement prevails; prior was not imposed, no relief allowed
Scope of retroactivity of new statute	Applies to any sentence, regardless of date of resentencing	Applies only to judgments entered before Jan. 1, 2020	Statute applies only to qualifying judgments imposed before Jan. 1, 2020
Court authority to correct unauthorized sentences	Not directly addressed	Court can correct unauthorized sentence at any time	Court acted properly in striking invalid enhancement

People v. Buycks, 5 Cal.5th 857 (Cal. 2018) (full resentencing appropriate after partial reversal and remand)
People v. Delgado, 43 Cal.4th 1059 (Cal. 2008) (oral pronouncement of sentence controls over abstract of judgment)
People v. Codinha, 92 Cal.App.5th 976 (Cal. Ct. App. 2023) (trial court may correct unauthorized sentences at any time)