People v. Williams CA4/3, G064661

Byron Lowe Williams pled guilty in 2015 to multiple felonies and admitted eight prison prior enhancements under former Penal Code section 667.5(b).
The trial court imposed one-year sentences for each enhancement but stayed them.
In 2022, Williams petitioned for recall and resentencing under Penal Code sections 1172.7 and 1172.75 following legislative changes invalidating most prison prior enhancements imposed before 2020.
The trial court denied the petition, reasoning that since the prison prior enhancements were stayed, not executed, Williams was ineligible for relief.
The trial court vacated and struck the stayed sentences, but Williams appealed the denial of relief.

Issue	Williams' Argument	State's Argument	Held
Eligibility for resentencing under § 1172.75 when enhancement was imposed but stayed	Williams: The statute covers all enhancements imposed, whether stayed or executed; intent is to reduce sentences for invalid prison priors	State: Only enhancements both imposed and executed qualify for relief; "imposed" means executed	The court sided with Williams, holding that enhancements imposed but stayed are also eligible for resentencing

People v. Gonzalez, 43 Cal.4th 1118 (Cal. 2008) (interpreted "impose" as "impose and execute" in the context of firearm enhancements, forming a basis for differing lower court interpretations)
People v. Rhodius, 97 Cal.App.5th 38 (Cal. Ct. App. 2023) (held § 1172.75 applies only to executed enhancements; disagreed with Christianson)
People v. Christianson, 97 Cal.App.5th 300 (Cal. Ct. App. 2023) (held § 1172.75 includes enhancements imposed but not executed; statutory purpose is reducing sentences)