People v. Wyly CA4/3
G064046
Cal. Ct. App.Jun 3, 2025Background
- In 1994, Stanley Wyly was convicted by a jury of second degree murder and related charges following the death of his infant son; he was the sole defendant.
- Wyly was sentenced to 20 years and four months to life in prison, and his conviction was previously affirmed on direct appeal.
- In 2024, Wyly filed a petition for resentencing under Penal Code section 1172.6, following 2019 legislative amendments restricting murder liability to actual killers or major participants acting with reckless indifference.
- The trial court reviewed the record, including jury instructions and verdict forms, found Wyly was the actual killer, and denied his petition without an evidentiary hearing.
- Wyly's appellate counsel found no arguable issues and requested independent review; Wyly was also given an opportunity to file his own brief but did not do so.
- The Court of Appeal independently reviewed the record and affirmed the trial court’s denial of the resentencing petition.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Eligibility for Resentencing under §1172.6 | Wyly could not be convicted of murder under amended law | Wyly was not eligible because he was the actual killer; new law does not change this | Wyly ineligible for resentencing; actual killer under current law |
| Prima Facie Case Requirement | Amendments require review for resentencing eligibility | Wyly did not make a prima facie showing due to record evidence he was the killer | No prima facie showing; summary denial appropriate |
| Application of Amended Murder Liability | Seeks relief under narrowed liability rules | Jury was not instructed on felony-murder or natural/probable consequences theories; sole killer | Amendments do not aid Wyly |
| Sufficiency of Appellate Review | Counsel found no issues; requested review | None filed by Wyly | No reversible error found; denial affirmed |
Key Cases Cited
- People v. Lewis, 11 Cal.5th 952 (Cal. 2021) (addresses standard for evaluating prima facie showing under section 1172.6 and procedures for reviewing resentencing petitions)
- People v. Strong, 13 Cal.5th 698 (Cal. 2022) (explains summary denial when record shows ineligibility as matter of law)
- People v. Delgadillo, 14 Cal.5th 216 (Cal. 2022) (sets appellate review procedures for no-issue briefs in postjudgment appeals)