People v. Superior Court of Riverside Cnty.
228 Cal. Rptr. 3d 394
| Cal. | 2018Background
- Defendant Pablo Ullisses Lara, Jr. was charged in adult criminal court in June 2016 for sexual offenses committed when he was 14–15; charges were filed before Proposition 57 took effect.
- Proposition 57 (effective Nov. 9, 2016) eliminated prosecutors’ power of direct filing for most juveniles and requires juvenile-court transfer hearings (§ 707) before treating juveniles as adults.
- After Prop 57’s passage Lara requested transfer to juvenile court; the trial court granted the request, the People sought writ relief, and the Court of Appeal denied the petition but held Lara was entitled to a fitness/transfer hearing.
- The Supreme Court granted review to decide whether Prop 57’s juvenile transfer-hearing requirement applies retroactively to cases filed in adult court before Prop 57’s effective date.
- The core legal question was whether Estrada’s inference that ameliorative criminal-law changes apply retroactively extends to an electorate-enacted procedural change that reduces potential punishment for juveniles.
- The Supreme Court concluded Prop 57’s transfer-hearing requirement is an ameliorative change analogous to those in Estrada/Francis and therefore applies retroactively to all juveniles whose judgments were not final when Prop 57 took effect; it affirmed the Court of Appeal’s judgment (though not its reasoning).
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Lara) | Held |
|---|---|---|---|
| Whether Prop 57’s ban on direct filing and requirement of juvenile transfer hearings applies retroactively to cases filed in adult court before Prop 57 took effect | Prop 57 is procedural or prospective; Estrada does not apply so no retroactivity | Prop 57 is ameliorative for juveniles; Estrada/Francis inference supports retroactive application to nonfinal cases | Held: Prop 57’s transfer-hearing requirement applies retroactively to juveniles with nonfinal judgments when Prop 57 took effect |
| Whether Estrada’s inference of retroactivity applies where the change alters possible punishment for a class (juveniles) rather than the punishment for a particular offense | Estrada limited (Brown/Conley): does not apply to changes not altering punishment for past conduct | Estrada applies because Prop 57 reduces possible punishment and can dramatically alter outcomes for juveniles | Held: Estrada’s rationale applies; Prop 57 yields ameliorative benefits to juveniles and inference of retroactivity stands |
| Whether existing remedial statutes (e.g., Penal Code § 1170.17) or practical complexity defeat retroactive relief | § 1170.17 and administrative/practical concerns show voters did not intend full retroactivity; complexity counsels against retroactive transfer hearings | § 1170.17 is distinct, less favorable, and does not rebut Estrada; complexity is inherent but manageable | Held: § 1170.17 does not rebut retroactivity inference; remedial procedures (like those in Vela/Cervantes) are available and complexity is not dispositive |
Key Cases Cited
- In re Estrada, 63 Cal.2d 740 (Cal. 1965) (ameliorative criminal-law changes are presumed to apply to nonfinal judgments)
- People v. Francis, 71 Cal.2d 66 (Cal. 1969) (Estrada inference applied where legislative change made reduced punishment possible)
- People v. Brown, 54 Cal.4th 314 (Cal. 2012) (distinguishes Estrada where statute affected future conduct incentives rather than punishment for past conduct)
- People v. Conley, 63 Cal.4th 646 (Cal. 2016) (explains limits to Estrada where the reform act contained its own explicit retroactivity scheme)
- People v. Vela, 11 Cal.App.5th 68 (Cal. Ct. App. 2017) (held Prop 57’s transfer-hearing requirement applied and outlined remedial approach for cases tried as adults pre-Prop 57)