People v. Meza CA2/2, B329872

Brayan Martin Meza was convicted of second-degree murder related to a gang shooting in which he provided a gun used to kill David Hendricks after a physical altercation.
Meza was found guilty by a jury, with sentencing enhancements for gang and firearm involvement, and received a 40-year sentence.
The jury was instructed on direct aiding and abetting liability using standard CALCRIM instructions but not on felony murder or the natural and probable consequences theory.
Meza previously filed two petitions for resentencing under Penal Code 1172.6, both denied without evidentiary hearings; these petitions predated statutory amendments expanding eligibility for relief.
After amendments to section 1172.6 broadened relief to convictions based on any imputed malice theory, Meza filed a third petition, which was also denied without an evidentiary hearing, prompting this appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Meza’s murder conviction rest on imputed malice under standard CALCRIM instructions?	Jury instruction required personal malice for aiding/abetting	Instructions allowed conviction based on imputed malice	Instructions do not foreclose imputed malice; evidentiary hearing required
Is Meza procedurally barred from a third petition after two similar prior petitions?	Prior petitions on same issue bar further relief	Statutory amendments expanded eligible relief after prior petitions	New amendments allow petition; not procedurally barred

People v. McCoy, 25 Cal.4th 1111 (Cal. 2001) (aider and abettor must share perpetrator’s specific intent; no imputed malice under old rule)
People v. Beeman, 35 Cal.3d 547 (Cal. 1984) (requiring specific intent for aider and abettor liability)
People v. Reyes, 14 Cal.5th 981 (Cal. 2023) (holding standard jury instructions allow conviction based on imputed malice; governs interpretation here)
People v. Maciel, 57 Cal.4th 482 (Cal. 2013) (aider and abettor must intend to aid commission of the crime)