People v. Williams CA2/2
B305302
| Cal. Ct. App. | Jun 21, 2021Background
- In 1976 Robert Lee Williams participated with others in robberies to obtain heroin; an elderly tenant, Minnie Devereaux, was beaten, stabbed and robbed and later died.
- Williams was convicted in 1978 of robbery, burglary and first-degree murder and sentenced to life.
- In March 2019 Williams filed a Penal Code § 1170.95 petition seeking resentencing under SB 1437 (which narrowed felony-murder liability).
- The superior court summarily denied the petition, concluding the record (including the prior appellate opinion) showed Williams was a major participant who acted with reckless indifference to human life and therefore ineligible as a matter of law.
- The Court of Appeal held the record of conviction did not conclusively establish ineligibility; the trial court improperly engaged in factfinding at the prima facie stage and should have issued an order to show cause and conducted an evidentiary hearing under § 1170.95(d).
- The appellate court reversed and remanded for issuance of an order to show cause and further proceedings, without deciding ultimate entitlement to relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court properly summarily denied Williams’s § 1170.95 petition | People: The record and prior opinion show Williams was a major participant who acted with reckless indifference, so he is ineligible as a matter of law. | Williams: The record does not conclusively show major-participant/reckless-indifference elements; prima facie review required issuing an order to show cause and a hearing. | Reversed — summary denial improper; order to show cause and § 1170.95(d) hearing required. |
| Scope of prima facie review under § 1170.95(c) | People: Court can rely on record to determine ineligibility. | Williams: Court may only consider readily ascertainable record facts and cannot undertake factfinding or credibility assessments. | Court may consult record for readily ascertainable facts but may not weigh evidence; factfinding reserved for post-OSC hearing. |
| Whether prior appellate opinion established imputed malice/old felony-murder theory bars relief | People: Prior opinion demonstrates conduct equivalent to major participant with reckless indifference. | Williams: Pre-SB 1437 convictions could be based on imputed malice; prior opinion does not establish elements required post-amendment. | Prior opinion did not conclusively establish the SB 1437 elements; it is insufficient to deny relief at prima facie stage. |
| Burden allocation after OSC under § 1170.95(d) | People: (implied) prosecution must prove ineligibility if hearing occurs. | Williams: (implied) once OSC issued, prosecution must disprove eligibility beyond a reasonable doubt. | If OSC issued, prosecution bears burden beyond a reasonable doubt to prove ineligibility at evidentiary hearing. |
Key Cases Cited
- People v. Gentile, 10 Cal.5th 830 (2020) (explaining SB 1437 amendments to malice and felony-murder law)
- People v. Drayton, 47 Cal.App.5th 965 (2020) (prima facie review limits and requirement for an OSC and evidentiary hearing when record is not dispositive)
- People v. Duchine, 60 Cal.App.5th 798 (2021) (courts must draw inferences for petitioner at prima facie stage and reserve factfinding for hearing)
- People v. Verdugo, 44 Cal.App.5th 320 (2020) (permissible scope of sua sponte record review at prima facie stage)
- People v. Lewis, 43 Cal.App.5th 1128 (2020) (trial court may screen petition using readily ascertainable record facts but should not resolve factual disputes)
- People v. Chun, 45 Cal.4th 1172 (2009) (describing pre-SB 1437 felony-murder rule and imputed malice)