People v. Walker, 16 Cal.5th 1024

Background

Maurice Walker was convicted in 2012 of assault with a deadly weapon and other offenses, along with sentencing enhancements, and sentenced to 20 years in prison (later reduced).
Two of Walker’s enhancements implicated new mitigatory rules under Penal Code section 1385, amended by Senate Bill No. 81 in 2021, which prescribed great weight be given to specified mitigating factors in considering dismissal of sentencing enhancements.
The trial court denied Walker’s resentencing motion to dismiss enhancements, choosing not to exercise its discretion under the amended statute.
The Court of Appeal affirmed, interpreting the amended statute as creating a rebuttable presumption in favor of dismissing enhancements unless doing so would endanger public safety—a view in conflict with a later case, People v. Ortiz.
The California Supreme Court granted review to resolve conflicting interpretations about whether Penal Code section 1385(c)(2) creates such a presumption, and to clarify how "great weight" for mitigation operates.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Penal Code § 1385(c)(2) create a rebuttable presumption in favor of dismissing enhancements absent endangerment to public safety?	No presumption, just that courts must give great weight to mitigating factors but retain discretion.	Yes, the presence of a mitigating factor requires dismissal unless there is a finding of public safety danger.	The statute does not create a rebuttable presumption; courts must assign great weight to mitigation but keep discretion.
What does “afford great weight” to mitigating factors mean?	Mitigating factors are given increased importance but balancing is holistic; courts may still consider countervailing aggravation.	"Great weight" should mean enhancements are dismissed unless there is substantial evidence to the contrary.	"Great weight" means strong consideration for dismissal but allows countervailing aggravating factors to justify retention of enhancements.
Is remand necessary under the clarified standard?	No; the judgment should be affirmed regardless of the Court of Appeal's reasoning.	Yes; the Court of Appeal should revisit in light of the correct standard.	No remand; defendant is not entitled to further relief under the correct, less restrictive interpretation.
Should dicta or legislative history (Martin, author letters) shape the “great weight” standard?	No; plain statutory language gives sufficient direction.	Yes; legislative intent shows alignment with existing "great weight" standards in case law.	No; statutory text and legislative process show intent not to import previous case law standards.

Key Cases Cited

People v. Lewis, 11 Cal.5th 952 (Cal. 2021) (re statutory interpretation framework, context, and legislative intent)
People v. Martin, 42 Cal.3d 437 (Cal. 1986) (interpretation of "great weight" in prior appellate context, discussed but not adopted)
People v. Jones, 51 Cal.3d 294 (Cal. 1990) (requirement that substantial evidence underpins aggravation factors in sentencing)