People v. Miller
A170047M
| Cal. Ct. App. | Jul 7, 2025Background
- Armani Miller was charged in Alameda County with murder, kidnapping, and robbery related to the 2015 killing of John Doe; the prosecution alleged that Miller was a major participant and acted with reckless indifference.
- Miller pled no contest to voluntary manslaughter (post-Senate Bill 1437) in August 2020, after initially pleading to second degree murder; he was sentenced to 16 years in prison.
- In May 2023, Miller filed a petition for resentencing under Penal Code section 1172.6, arguing he could not be convicted of murder under amended felony murder rules (post-2019 changes).
- The trial court denied the petition, finding Miller had not made a prima facie case for relief because the amended information was filed after the changes made by Senate Bill 1437.
- On appeal, Miller argued that new case law regarding youth as a factor in assessing "reckless indifference" made him eligible for relief, despite pleading after Senate Bill 1437's enactment.
Issues
| Issue | Miller's Argument | State's Argument | Held |
|---|---|---|---|
| Eligibility under section 1172.6(a)(1) | Amended law and recent cases on youth factor permit relief; info charged felony murder | Miller was charged after law changed; only old felony murder theory qualifies | Miller not eligible; info did not permit obsolete felony murder theory |
| "Felony murder" meaning under 1172.6 | Relief applies if any felony murder charged | Only applies to pre-1437 felony murder theory | "Felony murder" in this context means now-abolished, pre-1437 theory |
| Role of youth/expert evidence | Post-plea cases acknowledge youth as factor; exclusion prejudiced his defense | Miller pled after law changed; exclusion of testimony was waived by plea | Subsequent case law irrelevant; plea after statute change; exclusion was waived |
| Use of charging document timing | Unclear at time of plea whether new standards applied | Info filed under new law, precluding old theories | Charging document controls; relief unavailable if not charged under pre-1437 theory |
Key Cases Cited
- People v. Gentile, 10 Cal.5th 830 (Cal. 2020) (clarifies scope of SB 1437 felony murder reform)
- People v. Strong, 13 Cal.5th 698 (Cal. 2022) (defining contours of major participant/reckless indifference post-SB 1437)
- People v. Williams, 86 Cal.App.5th 1244 (Cal. Ct. App. 2022) (prima facie inquiry at 1172.6 stage)
- People v. Reyes, 97 Cal.App.5th 292 (Cal. Ct. App. 2023) (ineligibility based on charging document filed after SB 1437)
- Kaatz v. City of Seaside, 143 Cal.App.4th 13 (Cal. Ct. App. 2006) (interpretive canon of statutory construction)
- People v. Arias, 45 Cal.4th 169 (Cal. 2008) (ejusdem generis canon for statutory interpretation)
- Moore v. California State Bd. of Accountancy, 2 Cal.4th 999 (Cal. 1992) (statutory interpretation for similar items)