In re Gabriel M. CA4/2

CourtCalifornia Court of Appeal
DecidedJanuary 29, 2025
DocketE083978
StatusUnpublished

This text of In re Gabriel M. CA4/2 (In re Gabriel M. CA4/2) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Gabriel M. CA4/2, (Cal. Ct. App. 2025).

Opinion

Filed 1/29/25 In re Gabriel M. CA4/2

NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FOURTH APPELLATE DISTRICT

DIVISION TWO

In re GABRIEL M., a Person Coming Under the Juvenile Court Law.

THE PEOPLE, E083978 Plaintiff and Respondent, (Super.Ct.No. RIJ2100530) v. OPINION GABRIEL M.,

Defendant and Appellant.

APPEAL from the Superior Court of Riverside County. Mark Petersen, Judge.

Affirmed.

Aurora Elizabeth Bewicke, under appointment by the Court of Appeal, for

Rob Bonta, Attorney General, Lance E. Winters, Chief Assistant Attorney

General, Charles C. Ragland, Assistant Attorney General, Christopher P. Beesley and

Warren J. Williams, Deputy Attorneys General, for Plaintiff and Respondent.

1 Section 707 of the Welfare and Institutions Code “sets forth the procedures for

transferring a minor from juvenile court to criminal court.” (In re Miguel R. (2024) 100

Cal.App.5th 152, 164 (Miguel R.); unlabeled statutory references are to the Welfare and

Institutions Code.) The Legislature amended the provision in both 2023 and 2024.

(Ibid.)

In May 2024, the juvenile court ordered Gabriel M. transferred from the juvenile

court to criminal court under section 707. Gabriel appeals from that order. He argues

that the trial court prejudicially erred by either (1) failing to apply section 707 as it was

amended in 2024 by Senate Bill No. 545 (2023-2024 Reg. Sess.) (Senate Bill 545) (Stats.

2023, ch. 716, § 1) or (2) incorrectly applying the new law and not considering the

relevant factors that Senate Bill 545 required the court to consider. Gabriel also argues

that his trial counsel rendered ineffective assistance by failing to advocate against transfer

on the basis of the 2024 amendments. We reject Gabriel’s claims of error and conclude

that any deficient performance by trial counsel was harmless, and we therefore affirm.

LEGAL FRAMEWORK

Section 707 “provides that whenever a minor aged 16 years or older is alleged to

have committed a felony, the prosecutor may move ‘to transfer the minor from juvenile

court to a court of criminal jurisdiction.’ (§ 707, subd. (a)(1).)” (Miguel R., supra, 100

Cal.App.5th at p. 164.) “Upon receiving a transfer motion, the juvenile court is required

to ‘order the probation officer to submit a report on the behavioral patterns and social

history of the minor.’ (§ 707, subd. (a)(1).)” (Kevin P. v. Superior Court (2020) 57

2 Cal.App.5th 173, 186.) “The prosecution bears the burden of proving that the minor

should be transferred. (Cal. Rules of Court, rule 5.770(a).)” (Miguel R., at p. 164.)

Subdivision (a)(3) of section 707 (§ 707(a)(3)) now provides: “Following

submission and consideration of the report, and of any other relevant evidence that the

petitioner or the minor may wish to submit, the juvenile court shall decide whether the

minor should be transferred to a court of criminal jurisdiction. In order to find that the

minor should be transferred to a court of criminal jurisdiction, the court shall find by

clear and convincing evidence that the minor is not amenable to rehabilitation while

under the jurisdiction of the juvenile court. In making its decision, the court shall

consider the criteria specified in subparagraphs (A) to (E), inclusive. If the court orders a

transfer of jurisdiction, the court shall recite the basis for its decision in an order entered

upon the minutes, which shall include the reasons supporting the court’s finding that the

minor is not amenable to rehabilitation while under the jurisdiction of the juvenile

court.” (§ 707(a)(3), italics added.) The italicized language was added by Assembly Bill

No. 2361 (2021-2022 Reg. Sess.) (Assembly Bill 2361) and effective in January 2023.

(Stats. 2022, ch. 330, § 1; Miguel R., supra, 100 Cal.App.5th at p. 164.)

“The five statutory criteria listed in subparagraphs (A) through (E) of section

707(a)(3) were not amended by Assembly Bill 2361. Those criteria are (1) ‘the degree of

criminal sophistication exhibited by the minor’ (§ 707, subd. (a)(3)(A)(i)), (2) ‘[w]hether

the minor can be rehabilitated prior to the expiration of the juvenile court’s jurisdiction’

3 (§ 707[, subd.] (a)(3)(B)(i)), (3) ‘[t]he minor’s previous delinquent history’ (§ 707, subd.

(a)(3)(C)(i)), (4) ‘[s]uccess of previous attempts by the juvenile court to rehabilitate the

minor’ (§ 707, subd. (a)(3)(D)(i)), and (5) ‘[t]he circumstances and gravity of the offense

alleged in the petition to have been committed by the minor’ (§ 707, subd.(a)(3)(E)(i)).

The statute sets forth a nonexhaustive list of relevant factors for the court to consider with

respect to each of the five criteria. (§ 707, subd. (a)(3)(A)(ii), (B)(ii), (C)(ii), (D)(ii),

(E)(ii).)” (Miguel R., supra, 100 Cal.App.5th at p. 164.) These criteria “are based on the

premise that the minor did, in fact, commit the offense.” (People v. Superior Court

(Jones) (1998) 18 Cal.4th 667, 682.)

Effective January 2024, Senate Bill 545 “amended section 707 to require that with

respect to each of those five criteria the juvenile court ‘shall give weight to any relevant

factor,’ including the specific factors listed as relevant to each criterion. (§ 707, subd.

(a)(3)(A)(ii), (B)(ii), (C)(ii), (D)(ii), (E)(ii).)” (Miguel R., supra, 100 Cal.App.5th at

p. 164.) “The previous version of the statute made consideration of those factors

discretionary, not mandatory. (Former § 707, subd. (a)(3)(A)(ii), (B)(ii), (C)(ii), (D)(ii),

(E)(ii).) With respect to the degree of criminal sophistication, Senate Bill 545 also added

new mandatory factors for the court to consider: whether the minor has had any

involvement in the child welfare or foster care system and whether the minor has been ‘a

4 victim of human trafficking, sexual abuse, or sexual battery.’ (§ 707, subd.

(a)(3)(A)(ii).)”1 (Miguel R., at pp. 164-165; Stats. 2023, ch. 716, § 1.)

BACKGROUND

I. Delinquency history

In September 2021, Gabriel was declared a ward of the court when he was 17

years old. He admitted committing felony grand theft in violation of Penal Code section

487, subdivision (c). According to the detention report, the offense occurred at Jurupa

Valley High School, where Gabriel got in another student’s face and said, “‘You’re my

bitch, I’m going [t]o fuck you up,’” took the student’s hat off of his head, yanked a chain

off the student’s neck, punched the student in the face, and ran away with the hat and the

1 The listed relevant factors for the five criteria are: “the minor’s age, maturity, intellectual capacity, and physical, mental, and emotional health at the time of the alleged offense; the minor’s impetuosity or failure to appreciate risks and consequences of criminal behavior; the effect of familial, adult, or peer pressure on the minor’s actions; the effect of the minor’s family and community environment; the existence of childhood trauma; the minor’s involvement in the child welfare or foster care system; and the status of the minor as a victim of human trafficking, sexual abuse, or sexual battery on the minor’s criminal sophistication” (§ 707, subd.

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
People v. Williams
948 P.2d 429 (California Supreme Court, 1998)
People v. Superior Court (Jones)
958 P.2d 393 (California Supreme Court, 1998)
People v. Crittenden
885 P.2d 887 (California Supreme Court, 1994)
Hinton v. Alabama
134 S. Ct. 1081 (Supreme Court, 2014)
Ace American Insurance Co. v. Fireman's Fund Insurance Co.
2 Cal. App. 5th 159 (California Court of Appeal, 2016)

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In re Gabriel M. CA4/2, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-gabriel-m-ca42-calctapp-2025.