108 Cal.App.5th 791
Cal. Ct. App.2025Background
- Mariano Valdez was convicted of first-degree murder committed at age 17 and was originally sentenced to life without parole (LWOP) plus 25 years to life.
- In 2018, after serving over 15 years, Valdez was resentenced under Penal Code §1170(d)(1) to 50 years to life, making him eligible for youth offender parole.
- In 2023, Valdez, after being denied parole, petitioned again for resentencing, this time under §1170(d)(10), arguing his sentence remains the functional equivalent of LWOP per People v. Heard.
- The trial court granted Valdez’s petition, holding that denying relief under §1170(d)(10) would violate equal protection for juveniles sentenced to the functional equivalent of LWOP.
- The People filed for a writ of mandate to compel the trial court to deny further resentencing relief, arguing Valdez is not serving an LWOP-equivalent sentence post-resentencing.
Issues
| Issue | People’s Argument | Valdez’s Argument | Held |
|---|---|---|---|
| Is a 50-to-life sentence after §1170(d)(1) resentencing the functional equivalent of LWOP where youth parole is available? | 50-to-life w/parole is not LWOP or its equivalent; Franklin controls | Sentence is functionally LWOP under Contreras and Heard | 50-to-life w/parole eligibility is not LWOP; Franklin is binding |
| Does Heard require resentencing relief under §1170(d)(10) for LWOP-equivalent sentences post-resentencing? | Heard is distinguishable; Heard/Sorto wrongly decided | Heard’s equal protection reasoning extends to §1170(d)(10) | Heard/Sorto do not require relief; relevant sentence is post-resentencing |
| Does eligibility for youth offender parole affect whether a sentence is LWOP-equivalent? | Yes, parole eligibility means not LWOP-equivalent | Parole eligibility does not make the sentence less severe | Parole eligibility renders sentence not LWOP-equivalent |
| Did the trial court err in granting the §1170(d)(10) resentencing petition? | Yes, legal standards not met | No, equal protection requires relief | Yes, trial court erred; petition for mandate granted |
Key Cases Cited
- Graham v. Florida, 560 U.S. 48 (2010) (held Eighth Amendment bars LWOP for juveniles in non-homicide cases)
- Miller v. Alabama, 567 U.S. 460 (2012) (mandatory LWOP for juveniles violates the Eighth Amendment)
- People v. Caballero, 55 Cal.4th 262 (Cal. 2012) (sentence with parole ineligibility beyond life expectancy is de facto LWOP for juveniles)
- People v. Franklin, 63 Cal.4th 261 (Cal. 2016) (youth parole eligibility after 25 years means sentence is not LWOP-equivalent)
- People v. Contreras, 4 Cal.5th 349 (Cal. 2018) (50-to-life sentences for non-homicide juveniles without parole are LWOP-equivalent)