Teal v. Superior Court
60 Cal. 4th 595
| Cal. | 2014Background
- Bennie Jay Teal was serving an indeterminate 25-years-to-life sentence under California's Three Strikes law after a 1996 conviction for making a criminal threat (§ 422) and at least two prior serious felonies.
- Proposition 36 (Three Strikes Reform Act of 2012), effective Nov. 7, 2012, limited life sentences to cases where the third strike is a serious or violent felony and created Penal Code § 1170.126 allowing petitions to recall third-strike life sentences that are not for serious/violent felonies.
- On Dec. 6, 2012 Teal filed a § 1170.126 petition arguing his current offense was not a serious felony at the time of conviction; the trial court denied the petition, finding the offense is now defined as a "serious" felony.
- Teal appealed; the Court of Appeal held the denial was not appealable and treated his notice of appeal as a writ petition, then denied relief on the merits for a separate reason (a prior rape conviction qualifying as a disqualifying offense).
- The California Supreme Court granted review to decide whether denial of a § 1170.126 petition is an appealable order under Penal Code § 1237(b).
- The Supreme Court held the trial court’s denial of a § 1170.126 petition is an appealable postjudgment order under § 1237(b) because § 1170.126 creates a substantial right to seek resentencing and denial affects that right.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is a trial court's denial of a § 1170.126 petition appealable under § 1237(b)? | Teal: Denial is appealable because § 1170.126 creates a statutory postjudgment right to resentencing; denial affects substantial rights. | AG: Not appealable because petitioner lacked eligibility/standing; threshold eligibility is jurisdictional so denial doesn’t affect substantial rights. | Held: Appealable. § 1170.126 creates a substantial right; denial of the petition is an order after judgment affecting substantial rights under § 1237(b). |
Key Cases Cited
- People v. Yearwood, 213 Cal.App.4th 161 (discusses pre-Act Three Strikes consequences)
- People v. Wende, 25 Cal.3d 436 (mandated appellate independent review when appointed counsel finds no arguable issues)
- People v. Totari, 28 Cal.4th 876 (appealability of denial of postjudgment relief under § 1237(b))
- People v. Mena, 54 Cal.4th 146 (orders denying motions that affect substantial rights are appealable)
- People v. Gamache, 48 Cal.4th 347 (appellate review of sentencing errors that affected substantial rights)
- People v. Mazurette, 24 Cal.4th 789 (appealability is statutory)
- Holmes v. California Nat. Guard, 90 Cal.App.4th 297 (standing requires concrete beneficial interest)
- People v. Superior Court (Kaulick), 215 Cal.App.4th 1279 (claims of unlawful sentence may be raised on appeal)
- People v. Coleman, 86 Cal.App.3d 746 (denials of relief that prolong commitment are appealable)