People v. Williams CA2/3, B333816

Darren Charles Williams was convicted of four counts of first-degree murder for the 1984 shooting deaths of Ebora Alexander, her daughter, and two grandsons in Los Angeles.
Witnesses testified Williams masterminded a murder-for-hire scheme, recruited accomplices, planned the attack, and entered the home where the murders occurred.
Williams's conviction was initially for first-degree murder, later reduced to second-degree murder in response to legal changes affecting accomplice liability under the felony murder rule.
Williams filed a resentencing petition under Penal Code § 1172.6 following legislative amendments (SB 1437, SB 775) that narrowed accomplice murder liability.
The trial court denied the petition, finding Williams remained guilty beyond a reasonable doubt under current law, based on direct and conspiracy theories involving express and implied malice, and as a major participant with reckless indifference to life.
On appeal, Williams argued for reconsideration based on his youth at the time of the offense and requested a Franklin hearing to create a record for future parole consideration.

Issue	Williams's Argument	State's Argument	Held
Whether the trial court erred by failing to consider Williams’s youth in assessing his mental state for murder	Court must consider his youth (age 24) as potentially negating the required mental state; failure to do so was legal error	Williams forfeited this claim by not raising it below; law at the time provided opportunity to present such arguments	Forfeiture applies; even if considered, any error was harmless given evidence of planning and leadership, not immaturity
Whether Williams was entitled to resentencing under § 1172.6 post-SB 1437/SB 775	Evidence insufficient to show express or implied malice; only drove another to the scene	Williams led, planned, armed, and participated as a major actor with intent to kill	Resentencing denied; finding of guilt stands under multiple theories, including major participant with reckless indifference
Whether the trial court was required to remand for a Franklin hearing	Remand required to build record for youthful offender parole hearing	Opposed remand; argued Franklin issue was separate and could be addressed via new motion	No remand; Franklin request should be directed to the trial court in a separate proceeding

People v. Franklin, 63 Cal.4th 261 (Cal. 2016) (Franklin hearings establish youth offender parole hearing records)
People v. Chiu, 59 Cal.4th 155 (Cal. 2014) (limits natural and probable consequences doctrine in murder liability)
People v. Gentile, 10 Cal.5th 830 (Cal. 2020) (interprets SB 1437 and accomplice liability reform)
People v. Lewis, 11 Cal.5th 952 (Cal. 2021) (sets procedures for § 1172.6 resentencing petitions)
People v. Strong, 13 Cal.5th 698 (Cal. 2022) (clarifies prosecution burden at § 1172.6 evidentiary hearings)