People v. Brissette CA2/4

CourtCalifornia Court of Appeal
DecidedJanuary 30, 2026
DocketB338984
StatusUnpublished

This text of People v. Brissette CA2/4 (People v. Brissette CA2/4) 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
People v. Brissette CA2/4, (Cal. Ct. App. 2026).

Opinion

Filed 1/30/26 P. v. Brissette CA2/4 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

SECOND APPELLATE DISTRICT

DIVISION FOUR

THE PEOPLE, B338984 (Los Angeles County Plaintiff and Respondent, Super. Ct. No. KA062643)

v.

PHILLIP MAURICE BRISSETTE,

Defendant and Appellant.

APPEAL from postconviction orders of the Superior Court of Los Angeles County, Jacqueline Lewis and Robert Serna, Judges. Affirmed. James M. Crawford, under appointment by the Court of Appeal, for Defendant and Appellant. Rob Bonta, Attorney General, Charles C. Ragland, Chief Assistant Attorney General, Susan Sullivan Pithey, Senior Assistant Attorney General, Wyatt E. Bloomfield, Supervising Deputy Attorney General, and Charles Chung, Deputy Attorney General, for Plaintiff and Respondent. Defendant Phillip Maurice Brissette appeals from orders following initial and subsequent Penal Code section 1172.75 resentencing hearings.1 He contends the resentencing court erred by reimposing his original, upper base-term sentence without applying changes to section 1170 that limit imposition of an upper term sentence. He also contends the court failed to calculate actual time credits at the subsequent resentencing hearing. We accept the Attorney General’s concession on the latter contention. The former contention is presently before the California Supreme Court. Pending the Court’s decision, we join the majority of courts that have considered the issue and uphold the resentencing court’s authority to reinstate an upper base- term sentence.

BACKGROUND Pursuant to a negotiated agreement, on May 27, 2004, defendant pleaded no contest to attempted murder (§§ 664/187, subd. (a)), admitted he personally and intentionally discharged a firearm during its commission (§ 12022.53, subd. (c)), and admitted suffering a prior prison term (former § 667.5, subd. (b); hereinafter former § 667.5(b)).2 The court accepted the plea, admissions, and stipulation to a factual basis. In accordance with the plea, the court sentenced defendant to the upper term of

1 Subsequent references to statutes are to the Penal Code. 2 In exchange for his plea, the People dismissed another count of attempted murder (§§ 664/187, subd. (a)), one count of shooting at an inhabited dwelling (§ 246), and felon in possession of a firearm (former § 12021, subd. (a)(1)). All charged counts and enhancements exposed defendant to 80 years to life.

2 nine years for attempted murder, plus 20 years for the firearm enhancement and one year for serving a prior prison term. Defendant was credited with 378 days actual time and 56 days conduct credit. In April 2023, the matter was placed on calendar after the trial court received notice that defendant’s name appeared on the California Department of Corrections and Rehabilitation’s list of inmates eligible for possible resentencing under section 1172.75. The court appointed defendant counsel and received briefing from the parties. At an initial resentencing hearing on June 26, 2024, the People opposed defendant’s request to decrease his upper base- term sentence for attempted murder and reconsider the firearm enhancement in light of sections 1172.75 and 1170, subdivision (b)(1). The court struck the former section 667.5(b) one-year enhancement, declined defendant’s request to impose a lower base-term sentence, and reimposed the remaining portions of his sentence for a total of 29 years. In doing so, the court invoked section 1172.75, subdivision (d)(4) (hereinafter section 1172.75(d)(4)). The court calculated 7,335 days of actual custody credit days from the date of original sentencing. The court held another resentencing hearing on December 4, 2024, to determine whether People v. Stamps (2020) 9 Cal.5th 685 (Stamps) applied at resentencing. (See id. at pp. 707–708 [prohibiting ability to strike portion of negotiated sentence at resentencing without allowing parties to withdraw from underlying plea agreement].) Following the same arguments made at the previous hearing, the court again declined to modify defendant’s sentence beyond striking the former 667.5(b) enhancement. The court reimposed the 29-year

3 sentence and ordered the California Department of Corrections and Rehabilitation to “calculate the credits.” Defendant appealed.

DISCUSSION A. Reimposing Upper Term Sentence at Resentencing Defendant contends the resentencing court misapplied section 1172.75 when reimposing his upper base-term sentence absent his stipulation or a jury verdict supporting any factor used to aggravate the sentence. We review the court’s resentencing decision for abuse of discretion (People v. Mathis (2025) 111 Cal.App.5th 359, 366, review granted Aug. 13, 2025, S291628 (Mathis)) and questions of statutory interpretation de novo (People v. Superior Court (Guevara) (2025) 18 Cal.5th 838, 856). In 2022, the Legislature retroactively invalidated all enhancements imposed under former section 667.5(b) for non- sexually violent offenses. (See Stats. 2021, ch. 728, § 3; Stats. 2022, ch. 58, § 12.) Section 1172.75 lays out the process for resentencing inmates serving a term for a judgment that includes the invalidated enhancement. Beyond eliminating the one-year enhancement imposed for serving a prior prison term, section 1172.75 directs the resentencing court to appoint counsel (§ 1172.75, subd. (d)(5)), “apply any other changes in law that reduce sentences” (subd. (d)(2)), consider factors reflecting changed circumstances (subd. (d)(3)), and impose a sentence no greater than originally imposed (subd. (d)(1)). The last directive, invoked by the court below and raised by the parties here, provides: “Unless the court originally imposed the upper term, the court may not impose a sentence exceeding the

4 middle term unless there are circumstances in aggravation that justify the imposition of a term of imprisonment exceeding the middle term, and those facts have been stipulated to by the defendant, or have been found true beyond a reasonable doubt at trial by the jury or by the judge in a court trial.” (§ 1172.75(d)(4).)

Courts are presently divided on the meaning of this provision. Most cases construe section 1172.75(d)(4) to permit reimposition of an upper term sentence at resentencing without the defendant’s stipulation to, or jury determination of, any aggravating fact(s). (E.g., People v. Dozier (2025) 116 Cal.App.5th 700, 713 (Dozier); Mathis, supra, 111 Cal.App.5th at p. 373; People v. Brannon-Thompson (2024) 104 Cal.App.5th 455, 466–467 (Brannon-Thompson).) One published decision does not. (See People v. Gonzalez (2024) 107 Cal.App.5th 312, 329 (Gonzalez).)3 Citing Gonzalez, defendant contends the resentencing court erred when reimposing his upper base-term sentence. Consistent with Mathis and Brannon-Thompson, the Attorney General contends section 1172.75(d)(4) “provides a specific exception” applicable to those like defendant who were originally sentenced to an upper term. (See Mathis, supra, 111 Cal.App.4th at p. 374.) We join the cases agreeing with Mathis and Brannon- Thompson. Section 1172.75(d)(4) is clear. The first clause— “Unless the court originally imposed the upper term”—provides

3 The Supreme Court has granted review to consider this question. (See People v. Eaton (Mar. 14, 2025, C096853) [nonpub. opn.], review granted May 14, 2025, S289903.)

5 an exception to the second clause’s quantum of proof requirement for imposing an upper term at resentencing. (Mathis, supra, 111 Cal.App.5th at p. 374; Brannon-Thompson, supra, 104 Cal.App.5th at pp.

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People v. Brissette CA2/4, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-brissette-ca24-calctapp-2026.