48 Cal.App.5th 914
Cal. Ct. App.2020Background
- In 2010 Sanchez was charged with first degree murder (gang enhancement); in 2011 a voluntary manslaughter count (with gang enhancement) was added.
- Sanchez pled guilty to voluntary manslaughter, admitted a gang enhancement and an out-on-bail enhancement, and provided a factual basis that he and fellow gang members assaulted a presumed rival, causing the victim to hit his head on pavement.
- He was sentenced to an aggregate term of 23 years.
- After Senate Bill No. 1437, Sanchez petitioned under Penal Code § 1170.95 seeking resentencing, arguing he had accepted a plea to avoid a murder conviction under now-invalid theories.
- The trial court denied the petition, concluding § 1170.95 applies only to murder convictions; the Court of Appeal affirmed.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Sanchez) | Held |
|---|---|---|---|
| Whether § 1170.95 applies to persons who pled to voluntary manslaughter to avoid trial on murder charges | § 1170.95 expressly applies only to persons "convicted of felony murder or murder under a natural and probable consequences theory"; manslaughter is not covered | The plea clause in § 1170.95(a)(2) is ambiguous because it references pleas without expressly requiring the plea be to murder; statute should be read to include those who pled to manslaughter to avoid murder liability | § 1170.95 is unambiguous and limited to murder convictions; relief not available to voluntary manslaughter pleas |
| Whether § 1170.95 as written violates equal protection by treating similarly situated plea defendants differently | The Legislature rationally limited relief to murder because manslaughter carries lower penalties and SB 1437 targeted murder doctrines | Defendants who pleaded to manslaughter to avoid murder charges are similarly situated to those who pleaded to murder; exclusion is arbitrary | Applying rational-basis review, the classification is rationally related to legitimate legislative purposes; no equal protection violation |
Key Cases Cited
- People v. Flores, 44 Cal.App.5th 985 (Cal. Ct. App. 2020) (concluding § 1170.95 limited to murder convictions)
- People v. Turner, 45 Cal.App.5th 428 (Cal. Ct. App. 2020) (same)
- People v. Cervantes, 44 Cal.App.5th 884 (Cal. Ct. App. 2020) (same)
- People v. Prunty, 62 Cal.4th 59 (Cal. 2015) (governs independent review and statutory interpretation principles)
- People v. Rajanayagam, 211 Cal.App.4th 42 (Cal. Ct. App. 2012) (articulates rational-basis review for classifications in sentencing statutes)