People v. Garcia CA4/2

CourtCalifornia Court of Appeal
DecidedDecember 8, 2022
DocketE077916
StatusUnpublished

This text of People v. Garcia CA4/2 (People v. Garcia 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
People v. Garcia CA4/2, (Cal. Ct. App. 2022).

Opinion

Filed 12/8/22 P. v. Garcia CA4/2 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

THE PEOPLE,

Plaintiff and Respondent, E077916

v. (Super.Ct.No. CR47377)

JOSEPH GARCIA, OPINION

Defendant and Appellant.

APPEAL from the Superior Court of Riverside County. Charles J. Koosed, Judge.

Affirmed.

Robert Booher, under appointment by the Court of Appeal, for Defendant and

Appellant.

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

General, Charles C. Ragland , Assistant Attorney General, Melissa Mandel and Seth M.

Friedman, Deputy Attorneys General, for Plaintiff and Respondent.

1 In 1994, a jury convicted Joseph Garcia of second degree murder arising from his

involvement in a gang-related shooting. In 2019, he petitioned for relief under a new

provision allowing people serving time for certain murder convictions to petition to take

advantage of recent changes in the law. (Pen. Code, former § 1170.95, Stats. 2022, ch. 1 58, § 10, eff. June 30, 2022.) After a hearing, the trial judge found beyond a reasonable

doubt that Garcia was guilty for implied-malice murder, a still valid theory after changes

to the substantive definition of murder.

Garcia argues the trial judge erred in several respects. First, he argues the judge

couldn’t find him guilty of implied-malice murder without finding he acted with reckless

indifference to human life. However, the “reckless indifference” requirement applies in

the context of a prosecution for felony murder. Implied malice stands on its own as a

valid basis for a murder conviction. Second, Garcia argues he is entitled to a new hearing

because the trial judge relied on materials inadmissible after the later enactment of Senate

Bill No. 775 (2021-2022 Reg. Sess) (Stats. 2021, ch. 551) (SB 775). We conclude the

evidence didn’t make a difference to the judge’s conclusions and any error was harmless.

Third, Garcia argues there was insufficient evidence he acted with implied malice. We

conclude the evidence was sufficient. Finally, Garcia argues he has a right to a jury trial

on his petition. We disagree.

We therefore affirm the order denying Garcia’s petition.

1 Effective June 30, 2022, Penal Code section 1170.95 has been renumbered as section 1172.6, without any substantive change. (People v. Saibu (2022) 81 Cal.App.5th 709, 715, fn. 3.) Because Garcia brought his petition before the change, we will use “section 1170.95” to refer to the provision and to Garcia’s petition.

2 I

FACTS

At the time of these events, Garcia was a member or former member and associate

of the Elsinore Vatos Locos (EVL), a criminal street gang in Lake Elsinore. Garcia’s

codefendant, Albert Guillen, was an EVL member.

In early November 1992, Guillen had a physical fight with another young man on

the street in Lake Elsinore. A witness named Eric V. described the fight to the jury. He

said the fight was between Guillen and a young African American man. Guillen was

losing the fight badly when someone pulled out a gun and handed it to him. Guillen

pointed the gun in the face of the other man, but then handed the gun back. At that point

people started coming out of a nearby business, and the fight broke up. As Guillen and

his fellows walked off, they yelled out “EVL.” Eric V. responded, “F-U-C-K EVL.” This

turned out to be an ill-advised remark.

On November 15, 1992, Eric V. saw Garcia in his neighborhood as he was

working on the transmission of his truck with his friend Paul R. Eric V. approached

Garcia to talk to him about recent violence in the neighborhood between local Latinos

and African Americans. Eric V. testified he thought Garcia might be able to do something

to calm the situation. After the two had talked, Eric V. went back to his truck with

another man, Brian M., who bought a small amount of marijuana from him and gave him

a ride back to his truck.

3 About 15 to 20 minutes later, Garcia, Guillen, Tapia, and some other EVL

members approached Eric V. at his truck. Eric V. said he recognized Guillen from the

prior incident. He said one of the men came up to him and said, “aren’t you the one from

Heald Street that said F-U-C-K EVL and Joe Garcia?” Eric V. said at that point the men

were swarming him. He said he saw Garcia and started saying “No, Joe, no,” but he

started getting hit. Garcia and at least two other gang members then beat and pistol-

whipped Eric until he was unconscious.

Paul R. said he heard yelling and got out from under Eric V.’s car and saw Guillen

holding Eric V. from behind and Garcia hitting him in the face, then another man ran up

with an automatic weapon and hit Eric V. in the head with the gun. Paul R. fled around

the corner for fear of being shot, and Eric V. didn’t regain consciousness until he was in

an ambulance to be taken to the hospital.

While the other men were beating Eric V., Tapias chased Brian M. as he ran back

to his car. Tapia was armed with a handgun and the gun went off as the two struggled,

and Tapia suffered a gunshot wound to the stomach. Brian M. was then shot twice,

including a fatal shot to the head. We know from the preliminary hearing transcript in his

case that the shooter was EVL member James Coronado.

On March 29, 1994, a Riverside County jury convicted Garcia of second murder

(Pen. Code, § 187) and assault with a firearm (Pen. Code, § 245, subd. (a)), found he

committed the crimes for the benefit of a street gang (Pen. Code, § 186.22, subd. (b)(1)),

4 and found a principal was armed with a firearm. (Pen. Code, § 12022, subd. (a)(1)).

Garcia admitted two serious-felony priors and a prison prior.

The trial judge sentenced Garcia to 26 years to life in prison. The sentence was

composed of a sentence of 15 years to life for the second degree murder conviction, one

year consecutive because a principal was armed, 10 years consecutive for the two

serious-felony priors, and concurrent or stayed terms for the remaining conviction and

allegations. Garcia appealed, and this court affirmed. (People v. Guillen (Feb. 2, 1996,

E014756) [nonpub. opn.].)

On March 27, 2019, Garcia filed a petition for resentencing under new Penal Code

section 1170.95 and, on September 25, 2020, the trial judge issued an order to show

cause.

At his original trial, the People prosecuted Garcia under a then still valid natural

and probable consequences theory. (People v. Guillen, supra, E014756 at pp. 4, 10.)

Garcia’s section 1170.95 petition argued he was entitled to resentencing because the

“natural and probable consequences” theory is no longer a valid basis for a murder

conviction and he could not be convicted of murder under an implied-malice theory. The

People responded that Garcia could still be convicted of murder because he had acted

with implied malice.

After considering the parties’ arguments, the transcripts from the original

proceedings, and the record of conviction, the trial judge denied Garcia’s petition. He

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People v. Garcia CA4/2, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-garcia-ca42-calctapp-2022.