People v. Meza CA2/1
B335096
Cal. Ct. App.Mar 21, 2025Background
- In 1991, Robert Anthony Meza was convicted of second-degree murder after beating Arsenio Beltran unconscious in a street, resulting in Beltran being struck and killed by a car.
- The jury was not instructed on felony murder, the natural and probable consequences doctrine, or any theory imputing malice based solely on aiding and abetting.
- Thirty years later, Meza petitioned for resentencing under California Penal Code section 1172.6, which provides relief for people convicted under now-invalid theories of murder liability.
- The superior court denied Meza’s petition after an evidentiary hearing, finding him both ineligible for relief as a matter of law and, alternatively, guilty of second-degree murder beyond a reasonable doubt under current law.
- Meza appealed, arguing errors in the court's legal conclusions, factfinding process, standard of proof, sufficiency of evidence, consideration of his youth, and cumulative error.
Issues
| Issue | Meza's Argument | State's Argument | Held |
|---|---|---|---|
| Eligibility under §1172.6 for implied malice | He is eligible because implied malice murder convictions can be revisited | Not eligible; conviction was not based on a now-invalid theory | Not eligible: conviction not affected by new law |
| Factfinding by the trial court | Court failed to act as independent factfinder | Court conducted proper evidentiary hearing and applied law | Court acted as independent factfinder |
| Standard for finding guilt | Wrong standard used—"could be convicted" not "guilty beyond doubt" | Proper standard was used: beyond a reasonable doubt | Proper standard applied |
| Sufficiency of evidence for implied malice | Evidence insufficient to support implied malice | Substantial evidence of Meza's conscious disregard for life | Evidence sufficient for implied malice |
| Consideration of youth | Court did not properly weigh his age (20) in assessing culpability | Court found 20-year-old can appreciate deadly risk | Court sufficiently considered youth |
| Cumulative error | Multiple minor errors warrant reversal | No errors, so no cumulative error | No cumulative error |
Key Cases Cited
- People v. Knoller, 41 Cal.4th 139 (Cal. 2007) (establishes standard for implied malice murder—an act with high degree of probability of death constitutes implied malice)
- People v. Clements, 75 Cal.App.5th 276 (Cal. Ct. App. 2022) (SB 1437 abolished natural and probable consequences doctrine, but did not change implied malice definition)
- People v. Reyes, 14 Cal.5th 981 (Cal. 2023) (clarifies application of SB 1437 for murder convictions under old doctrines)