People v. Cain

CourtCalifornia Court of Appeal
DecidedDecember 8, 2025
DocketB342911
StatusPublished

This text of People v. Cain (People v. Cain) 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. Cain, (Cal. Ct. App. 2025).

Opinion

Filed 12/8/25

CERTIFIED FOR PUBLICATION

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION SIX

THE PEOPLE, 2d Crim. No. B342911 (Super. Ct. No. CR22297) Plaintiff and Appellant, (Ventura County)

v.

TRACY CAIN,

Defendant and Respondent.

Respondent Tracy Cain was sentenced to death in 1988. The People appeal a trial court order recalling, inter alia, the death penalty sentence pursuant to Penal Code section 1172.75. 1 We hold that the “full resentencing rule” (allegedly triggered because of a now invalid one-year prior prison term enhancement) does not provide an appropriate vehicle to achieve respondent’s stated goal of nullifying the previously imposed sentence of death. He may now seek modification of the determinate portion of the judgment which is insignificant.

1 All statutory references are to the Penal Code. Respondent also contends that the instant appeal is premature. We reject this contention because the order “affects” the substantial rights of the People. We hold that an order vacating a judgment of death necessarily affects the substantial rights of the People. As we shall explain, the trial court is without power to enter an order nullifying the death penalty. This death sentence was affirmed by the California Supreme Court. It is final. Recall and resentencing as to the death sentence would violate section 1509, which was enacted by voter initiative. Section 1509 provides, “A writ of habeas corpus pursuant to this section is the exclusive procedure for collateral attack on a judgment of death.” 2 Thus, we reverse the trial court’s order recalling the death sentence. We affirm the order recalling the noncapital portions of respondent’s sentence. We remand the matter to the trial court for resentencing on the noncapital portions of the judgment. Factual and Procedural Background The People charged respondent with the “special circumstances” murders of William and Modena Galloway during a 1986 home invasion burglary. A jury found him guilty of two counts of first-degree murder (§§ 187, subd. (a), 189, subd. (a)),

2 Neither the superior court nor the Court of Appeal should “tinker” with a judgment of death affirmed by the California Supreme Court. Whether couched in stare decisis theory, law of the case theory, or the like, we should be loath to interfere with, alter, or amend such a judgment. The Legislature has not expressly said that a section 1172.75 challenge authorizes a superior court to vacate an affirmed death sentence. And, we doubt that the Legislature, by simple statute, can change the constitutional provisions for the implementation of the death penalty.

2 two counts of burglary (§ 459), and one count of robbery (§ 211). It found true several special circumstance allegations. For each murder, the jury imposed the death penalty. The trial court sentenced respondent to death. It imposed a consecutive determinate term of seven years: the high term of six years for burglary plus a one-year enhancement for a prior prison term under section 667.5, former subdivision (b). In 1995 the Supreme Court affirmed the judgment. (People v. Cain (1995) 10 Cal.4th 1, 18, cert. denied, Cain v. California (1996) 516 U.S. 1077 [133 L.Ed.2d 734].) Respondent’s subsequent petition for writ of habeas corpus was denied. (See Cain v. Chappell (9th Cir. 2017) 870 F.3d 1003, cert. denied, Cain v. Davis (2018) 586 U.S. 987 [202 L.Ed.2d 348].) In 2022 the California Department of Corrections and Rehabilitation identified respondent as potentially eligible for resentencing under section 1172.75 because the one-year enhancement for a prior prison term was invalid. 3 Respondent submitted points and authorities arguing that section 1172.75 requires a full resentencing hearing on all counts. He requested the trial court to exercise its discretion under

3 “Prior to January 1, 2020, section 667.5, subdivision (b)

required trial courts to impose a one-year sentence enhancement for each true finding on an allegation the defendant had served a separate prior prison term and had not remained free of custody for at least five years. [Citation.] . . . Effective as of January 1, 2020, Senate Bill No. 136 . . . amends section 667.5, subdivision (b) to limit its prior prison term enhancement to only prior prison terms for sexually violent offenses, as defined in Welfare and Institutions Code section 6600, subdivision (b).” (People v. Jennings (2019) 42 Cal.App.5th 664, 681.)

3 section 1385 to strike the special circumstance allegations to “allow [the] Court to impose a life-term with the possibility of parole.” He claimed the court could do so because his offense was committed before the passage of Proposition 115. 4 The People objected and argued that section 1172.75 does not apply to respondent because he is currently sentenced to death. They contended respondent’s petition was an impermissible collateral attack on that sentence, which can be challenged only by a petition for a writ of habeas corpus under section 1509. After taking the matter under submission, in October 2024 the trial court determined that respondent is eligible for resentencing. It reasoned: “Jurisdiction was given to courts to recall and resentence under [section] 1172.75. The jurisdiction does not conflict with the limitations imposed by [section] 1509 because this is not a collateral attack or even an attack. This was not a separate action filed by [respondent], and there is no error, illegality, or unauthorized sentence claimed. The Legislature

4 After respondent’s conviction, “Proposition 115, the ‘Crime

Victims Justice Reform Act,’ changed criminal law in several respects on June 6, 1990.” (Tapia v. Superior Court (1991) 53 Cal.3d 282, 286.) It added section 1385.1 to the Penal Code, which provides: “Notwithstanding Section 1385 or any other provision of law, a judge shall not strike or dismiss any special circumstance which is admitted by a plea of guilty or nolo contendere or is found by a jury or court as provided in Sections 190.1 to 190.5, inclusive.” The Supreme Court stated, “[A]s to most of Proposition 115’s provisions we see no reason to depart from the ordinary rule of construction that new statutes are intended to operate prospectively.” (Tapia, at p. 287.)

4 simply extended jurisdiction to a select group of individuals to require resentencing for an otherwise lawful sentence at the time it was imposed. There are no cases holding that such recall and resentencing statutes constitute a collateral attack.” At a subsequent hearing, the trial court vacated respondent’s entire sentence and said that it would resentence him “at a later time.” The trial court’s reasoning exalted form over substance. Regardless of how the section 1172.75 proceeding was initiated, it was, and is, a collateral attack on the judgment of death. (See discussion at pp. 14-18, post.) Section 1172.75 Section 1172.75 was enacted in 2021 and became effective on January 1, 2022. (Stats.2021, ch 728, § 3.) It provides: “Any sentence enhancement that was imposed prior to January 1, 2020, pursuant to subdivision (b) of Section 667.5, except for any enhancement imposed for a prior conviction for a sexually violent offense as defined in subdivision (b) of Section 6600 of the Welfare and Institutions Code is legally invalid.” (§ 1172.75, subd. (a).) “A defendant serving a term for a judgment that includes a now-invalid enhancement is entitled to resentencing. (§ 1172.75, subds. (a), (c).) To facilitate the process, the statute directs California's Department of Corrections and Rehabilitation . . .

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People v. Cain, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-cain-calctapp-2025.