People v. Frye CA3

CourtCalifornia Court of Appeal
DecidedJune 27, 2025
DocketC100851
StatusUnpublished

This text of People v. Frye CA3 (People v. Frye CA3) 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. Frye CA3, (Cal. Ct. App. 2025).

Opinion

Filed 6/27/25 P. v. Frye CA3 NOT TO BE PUBLISHED California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published,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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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 THIRD APPELLATE DISTRICT (Sutter) ----

THE PEOPLE, C100851

Plaintiff and Respondent, (Super. Ct. No. 26719)

v.

JOE EDWARD FRYE,

Defendant and Appellant.

At a resentencing proceeding under Penal Code section 1172.75, the trial court sentenced defendant Joe Edward Frye to 16 years to life imprisonment.1 Defendant appeals, arguing the court failed to consider relevant mitigating circumstances and the future risk to public safety when declining to strike his weapon enhancement. He also

1 Undesignated statutory references are to the Penal Code.

1 challenges the court’s determination that his case was “not unusual.” Finding no merit to these contentions, we affirm. I. BACKGROUND In 1980, defendant and two companions were traveling on a freight train. The victim, who spoke little or no English, joined them at a stop. Defendant told his companions that the victim would have to “ ‘give up some ass’ ” to travel with them or be killed. Defendant consumed wine. After the victim refused to submit to defendant’s sexual advances, defendant used a machete to force the victim to the boxcar’s door. Defendant then pushed the victim off the train; the victim died from his injuries shortly after he was discovered. A jury found defendant guilty of second degree murder (§ 187) and found true an allegation that defendant used a deadly or dangerous weapon (§ 12022, subd. (b)). Defendant admitted he had served a prior prison term (§ 667.5, subd. (b)). The trial court sentenced defendant to 15 years to life in prison for the murder conviction and one year each for the two enhancements. In 2022, the Department of Corrections and Rehabilitation informed the trial court that defendant was serving a sentence for a prior prison term enhancement declared legally invalid by what is now section 1172.75 (former section 1171.1). The trial court struck the sentence for the prior prison term enhancement and resentenced defendant to the same term for the murder conviction and deadly weapon enhancement, resulting in a new aggregate sentence of 16 years to life. Defendant appealed, arguing the trial court erred by concluding it had no authority to reconsider aspects of defendant’s sentence other than the sentence for the prior prison term. (People v. Frye (Nov. 28, 2023, C096975) [nonpub. opn.].) We held that defendant forfeited this claim by failing to argue this point below but elected to excuse the forfeiture. (Ibid.) We remanded the matter to the trial court for defendant to argue that his sentence should be further modified. (Ibid.)

2 On remand, the probation officer prepared an updated report. The probation officer interviewed defendant, who claimed he never told his companions he intended to kill the victim. Defendant acknowledged that his actions led to the victim’s death but claimed he did not think pushing the victim out of the train would kill him. Defendant felt he was framed for the murder. Defendant claimed he had not consumed alcohol since 2012. At the resentencing hearing, defendant asked the trial court to strike the weapon enhancement under section 1385. He submitted no briefing on the issue. Defense counsel argued at the hearing that it was “in the interest of justice to strike the [enhancement] inasmuch as it’s a single year and not ten years or something longer than that.” The court declined to dismiss the enhancement, explaining that it would not “be anywhere near the interest of justice to strike an additional enhancement” given defendant’s criminal history and the “horrific” nature of the murder involving a vulnerable victim. The court stated: “Mr. Frye, [from] what I have read in the probation report, has showed little insight or remorse to committing this offense or any previous offenses. He seems only concerned with when he will be able to get out of prison.” The court said defendant was presumptively ineligible for probation and that it did “not find that this is an unusual case.” The court sentenced defendant to 15 years to life for murder and one year for the weapon enhancement. Defendant timely appealed. II. DISCUSSION A. Section 1385 Defendant argues the trial court erred by not considering relevant mitigating circumstances when declining to strike the weapon enhancement under section 1385. He contends the court should have taken into account how application of the enhancement could result in a sentence of over 20 years (§ 1385, subd. (c)(2)(C)); how the current

3 offense was connected to mental illness (id., subd. (c)(2)(D)); and how the current offense was connected to prior victimization or childhood trauma (id., subd. (c)(2)(E)). This claim is forfeited because defendant did not raise these issues below. (See People v. Scott (1994) 9 Cal.4th 331, 353, 356.) Section 1385 assigns to the defendant the burden of proving the existence of a mitigating circumstance. (See § 1385, subd. (c)(2) [“the court shall consider and afford great weight to evidence offered by the defendant to prove that any of the mitigating circumstances in subparagraphs (A) to (I) are present” (italics added)].) Yet at no point in the resentencing did defendant even mention the mitigating circumstances he now claims the trial court failed to consider. The forfeiture doctrine precludes defendant from making this claim for the first time on appeal. (See People v. Fruits (2016) 247 Cal.App.4th 188, 208 [“[A] party cannot argue on appeal that the trial court erred in failing to conduct an analysis it was not asked to conduct”].) Defendant also contends the trial court failed to properly consider whether dismissing the enhancement would endanger public safety. According to defendant, the court was required to assess whether defendant would pose a “risk of danger in the future.” This claim is without merit. The trial court never made an express finding that dismissing the weapon enhancement would endanger public safety. Nor was it required to do so. “Section 1385, subdivision (a), requires a trial court to state its ‘reasons for the dismissal . . . orally on the record,’ but there is no similar statutory requirement when a court denies a request to dismiss an enhancement.” (People v. Bravo (2025) 107 Cal.App.5th 1144, 1157; see also People v. Brugman (2021) 62 Cal.App.5th 608, 637 [“ ‘The trial court is not required to state reasons for declining to exercise its discretion under section 1385’ [citations], and ‘is presumed to have considered all of the relevant factors in the absence of an affirmative record to the contrary’ ”].) That aside, section 1385 only calls for a public safety finding where one of the mitigating

4 circumstances listed in the statute is present. (See § 1385, subd. (c)(2) [“Proof of the presence of one or more of these circumstances weighs greatly in favor of dismissing the enhancement, unless the court finds that dismissal of the enhancement would endanger public safety” (italics added)].) Here, none of the enumerated mitigating circumstances were established, as defendant did not even argue they applied. Further, “even without ‘a finding that dismissal would endanger public safety,’ the trial ‘court retains the discretion to impose or dismiss enhancements provided that it assigns significant value’ to the presence of any listed mitigating circumstances.” (People v. Bravo, supra, 107 Cal.App.5th at p. 1157; see ibid.

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People v. Frye CA3, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-frye-ca3-calctapp-2025.