People v. Padilla
13 Cal.5th 152
Cal.2022Background
- In 1999 Padilla (age 16) was transferred to adult court after a fitness hearing, convicted of murder and conspiracy, and sentenced to life without parole (LWOP); his direct appeal concluded in 2001.
- After Miller v. Alabama and Montgomery v. Louisiana, Padilla obtained habeas relief: his LWOP sentence was vacated and he was resentenced twice (the second resentencing was vacated on appeal and remanded again).
- Proposition 57 (2016) requires juvenile charges be filed in juvenile court unless a transfer hearing justifies adult prosecution; it was held in Lara to be ameliorative and retroactive to nonfinal judgments under In re Estrada.
- The discrete question: does Proposition 57 apply at a resentencing that follows vacatur of a previously final LWOP sentence?
- The Attorney General conceded Padilla’s sentence was vacated (so the trial court regained jurisdiction) but argued Estrada should not reach all forms of nonfinality (distinguishing initial-review nonfinality from resentencing after vacatur); Padilla and amici urged full application of Estrada.
- The Supreme Court held Proposition 57 applies to Padilla’s resentencing because vacatur converted his judgment into a nonfinal one and Estrada’s presumption governs nonfinal cases.
Issues
| Issue | Plaintiff's Argument (People/AG) | Defendant's Argument (Padilla) | Held |
|---|---|---|---|
| Does Proposition 57 apply at resentencing after a sentence vacated on habeas? | Estrada’s presumption should not extend to all forms of nonfinality; resentencings after vacatur are distinguishable from cases not yet final on initial review. | Prop. 57 applies to any nonfinal judgment, including resentencings after vacatur. | Yes. Vacatur made Padilla’s judgment nonfinal; Estrada’s presumption applies and Prop. 57 governs resentencing. |
| Does vacatur on habeas convert a once-final judgment into a nonfinal one for retroactivity purposes? | A long-final case should remain final for Estrada purposes despite a collateral habeas attack. | Vacatur restores trial-court jurisdiction and the right to direct review of the new sentence, so the judgment is nonfinal. | Vacatur renders the judgment nonfinal; direct review of the new sentence is not merely collateral. |
| Do Miller/Montgomery violations permit harmless-error reweighing instead of vacatur/resentencing? | (Dissent/AG view) Reweighing could be analogized to Clemons harmless-error reweighing and leave finality intact. | Miller/Montgomery require a sentencing proceeding that actually considers youth; unlawful LWOP sentences are void and require vacatur/resentencing. | Miller and Montgomery require vacatur/resentencing where their mandates were not followed; harmless-error reweighing is inapplicable. |
| Are practical or temporal difficulties (decades elapsed) a bar to applying Prop. 57 at resentencing? | Retroactive application would create anomalous, impractical results and likely exceed voters’ intent. | Practical difficulties do not override Estrada’s presumption; Lara already addressed similar issues. | Practical concerns do not defeat retroactivity where judgment is nonfinal; Lara’s remedial framework controls. |
Key Cases Cited
- In re Estrada, 63 Cal.2d 740 (Cal. 1965) (presumes ameliorative criminal laws apply to cases not yet final)
- People v. Superior Court (Lara), 4 Cal.5th 299 (Cal. 2018) (applies Estrada to Proposition 57’s juvenile provisions)
- People v. Conley, 63 Cal.4th 646 (Cal. 2016) (discusses Estrada presumption for ameliorative changes)
- People v. Esquivel, 11 Cal.5th 671 (Cal. 2021) (treats scope of Estrada as covering all nonfinal judgments subject to constitutional limits)
- Miller v. Alabama, 567 U.S. 460 (U.S. 2012) (mandatory LWOP for juveniles unconstitutional; sentencer must consider youth)
- Montgomery v. Louisiana, 577 U.S. 190 (U.S. 2016) (Miller announced a substantive rule; unlawful juvenile LWOP sentences are void and must be remedied)
- Plaut v. Spendthrift Farm, Inc., 514 U.S. 211 (U.S. 1995) (limits on retroactive legislation altering final judicial decisions)
- Clemons v. Mississippi, 494 U.S. 738 (U.S. 1990) (appellate reweighing is not a sentencing proceeding and may be akin to harmless-error review)
- People v. McKenzie, 9 Cal.5th 40 (Cal. 2020) (Estrada cutoff is date case is reduced to final judgment; nonfinality includes ongoing probation/revocation appeals)