People v. Padilla CA1/2
A170695
| Cal. Ct. App. | Mar 11, 2025Background
- Ronnie Padilla was convicted in 2011 of attempted premeditated murder and other offenses stemming from a 2006 attack in jail.
- Evidence showed Padilla and an accomplice, both Sureño gang members, attacked a fellow inmate, causing life-threatening injuries.
- Padilla was sentenced to an aggregate term that included 18 years to life for the attempted murder; his conviction for unrelated aggravated kidnapping was later reduced on appeal, but the attempted murder sentence remained unchanged.
- In 2022, Padilla filed for resentencing under Penal Code section 1172.6 (formerly section 1170.95) following legislative amendments that limited certain murder and attempted murder convictions to those with specific intent or major participation.
- The trial court denied the petition at the prima facie stage, finding the jury had not been instructed on felony murder or the natural and probable consequences doctrine, and thus Padilla was ineligible for resentencing as a matter of law.
Issues
| Issue | Padilla's Argument | People's Argument | Held |
|---|---|---|---|
| Eligibility for resentencing under PC 1172.6 | Jury instructions allowed conviction for attempted murder on a theory of imputed malice, not limited to natural/probable consequences. | Padilla's jury was not instructed on felony murder or natural/probable consequences doctrine. | Padilla is ineligible for relief as the jury was not instructed on inapplicable doctrines. |
| Ambiguity of aiding and abetting instructions | Instructions were unclear, permitting conviction without specific intent to kill. | Instructions required finding intent to kill for both perpetrator and aider. | Instructions required specific intent to kill; no ambiguity warranting relief. |
| Application of other theories of imputed malice for attempted murder | Section 1172.6 applies to attempted murder from natural/probable consequences or imputed malice, justifying relief. | Statute allows relief for attempted murder only under natural/probable consequences doctrine. | Relief only for convictions under that doctrine; not for other imputed malice theories. |
| Effect of injury enhancement instructions | Enhancement instructions could allow imputation of another’s actions/intent for conviction. | Enhancement required guilt for attempted murder first, which already required intent to kill. | Enhancement did not affect the theory of liability for attempted murder conviction. |
Key Cases Cited
- People v. Lewis, 11 Cal.5th 952 (Cal. 2021) (Sets standards for prima facie review in resentencing petitions under section 1172.6)
- People v. McCoy, 25 Cal.4th 1111 (Cal. 2001) (Defines liability for aiding and abetting with intent to kill)
- People v. Smith, 37 Cal.4th 733 (Cal. 2005) (Attempted murder requires specific intent to kill)
- People v. Covarrubias, 1 Cal.5th 838 (Cal. 2016) (Affirms intent-to-kill requirement for attempted murder)