People v. Williams CA2/6, B332652

Travis Ron Williams was convicted in 1997 (at age 15) of first degree murder, second degree burglary, and arson, related to a home-invasion burglary and killing of a 75-year-old woman.
Williams was not found to be the actual shooter, but was considered a major participant and was tried as an adult.
In 2019, Williams filed a petition for resentencing under Penal Code § 1172.6 (formerly § 1170.95), following legislative changes limiting felony murder liability and providing retroactive relief to some defendants.
The trial court denied Williams’s petition without an evidentiary hearing; the appellate court reversed and remanded for an evidentiary hearing.
After a three-day evidentiary hearing, including expert testimony about Williams’s youth and trauma, the trial court again denied the resentencing petition, finding Williams acted with reckless indifference to human life.
Williams appealed, arguing the trial court failed to apply the correct standard in evaluating whether his youth negated the requisite mental state for felony murder.

Issue	Williams’s Argument	State’s Argument	Held
Application of proper legal standard for youth	Trial court did not adequately consider his youth or psychological evidence; unclear record.	All relevant factors (including youth) were argued and considered by the court.	Court properly considered youth; order affirmed.
Weighing of psychiatric evidence	Trial court undervalued Dr. Elizondo’s trauma-related findings.	Court was not bound by one expert; could consider all evidence.	Court not required to adopt expert’s view.
Requirement to provide detailed rationale	Lack of written rationale creates ambiguity about legal standard application.	Rationale not required; only legal correctness of ruling matters.	No error; record supports proper legal application.
Relevance of youth to reckless indifference	Age should have negated finding of reckless indifference; court referenced parole as more appropriate.	Youth considered but did not outweigh evidence of reckless indifference.	Youth did not negate finding of reckless indifference.

People v. Reyes, 14 Cal.5th 981 (Cal. 2023) (clarifies limitations to felony-murder rule after legislative reforms)
People v. Lewis, 11 Cal.5th 952 (Cal. 2021) (evidentiary hearing requirements for § 1172.6 petitions)
People v. Gentile, 10 Cal.5th 830 (Cal. 2020) (retroactive relief and legal standards under amended felony-murder rule)
People v. Strong, 13 Cal.5th 698 (Cal. 2022) (burden of proof and procedure under § 1172.6)
Miller v. Alabama, 567 U.S. 460 (2012) (youth’s hallmark features relevant to culpability assessment)