People v. Williams, 199 Cal. Rptr. 3d 755

Prop. 47 (Pen. Code, § 1170.18) downgraded certain felonies/wobblers to misdemeanors and authorizes redesignation of completed sentences as misdemeanors.
Section 667.5, subdivision (b) requires a court to add one year for each prior separate prison term when sentencing for a felony.
Defendant Williams was sentenced in 2013 for eight counts, including a large grand theft and a prior felony burglary designated as a strike, plus prior prison terms.
In 2015, Williams obtained Proposition 47 redesignation of a petty theft with a prior conviction, reducing it to a misdemeanor.
Williams then moved to resentence the felony grand theft case to erase the 667.5(b) enhancement, arguing retroactive effect from the redesignation.
The trial court denied the motion, holding the 667.5(b) enhancement does not unravel when a related underlying offense is redesignated.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Prop. 47 redesignation retroactively affect 667.5(b) enhancements?	Williams argues redesignation retroactively removes the prior prison term basis.	People contends redesignation is prospective only and does not undo the enhancement.	No retroactive effect for 667.5(b) enhancement.
Does Prop. 47's 'misdemeanor for all purposes' apply retroactively when underlying offense is redesignated?	Williams urges retroactive redesignation applies to the enhancement outcome.	People maintains redesignation is prospective, with no retroactive unraveling of prior status.	Redesignation operates prospectively, not retroactively.
Does equal protection require retroactive redesignation or resentencing here?	Williams asserts unequal treatment of those with retroactive redesignation versus not.	People argues no equal protection violation given the legislative aims and limited scope.	No equal protection violation.

People v. Lynall, 233 Cal.App.4th 1102 (Cal. Ct. App. 2015) (Prop. 47 redesigned offenses apply prospectively; retroactivity not granted)
People v. Valenzuela, 244 Cal.App.4th 692 (Cal. Ct. App. 2016) (Prop. 47 applications must be filed in the trial court; redesignation not retroactive)
People v. Ruff, 244 Cal.App.4th 935 (Cal. Ct. App. 2016) (reaffirmed nonretroactivity of Prop. 47 redesignations)
People v. Carrea, 244 Cal.App.4th 966 (Cal. Ct. App. 2016) (Prop. 47 redesignation not retroactive; equal application binding)
People v. Diaz, 238 Cal.App.4th 1323 (Cal. Ct. App. 2015) (where to file petition for redesignation; effects on retroactivity discussed)
People v. Park, 56 Cal.4th 782 (Cal. 2013) (textual/policy interpretation guiding Prop. 47 analysis)