People v. Harrison

CourtCalifornia Court of Appeal
DecidedDecember 11, 2025
DocketA170760
StatusPublished

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

Opinion

Filed 12/10/25

CERTIFIED FOR PUBLICATION

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION FOUR

THE PEOPLE, Plaintiff and Respondent, A170760 v. (Solano County BRYANT EUGENE HARRISON, Super. Ct. No. WR2400393) Defendant and Appellant.

Defendant Bryant Eugene Harrison, a military veteran, was sentenced in 1995 to an indeterminate life sentence for assaulting and causing the death of a child under Penal Code section 273ab. 1 The offense was his first and only felony conviction. In 2024, Harrison filed a resentencing petition under section 1170.91, which allows a trial court to consider reducing the sentence of qualified military veterans who may have suffered from service- related conditions. He now appeals from the trial court’s summary denial of that petition. The narrow issue presented here is whether Harrison was entitled to a hearing on his petition. Contending that the legislative history of the amendment to section 1170.91 in 2022 shows that a major purpose of the Legislature was to expand the statute’s benefits to indeterminately sentenced defendants, Harrison argues he was entitled to a hearing under section

1 Undesignated statutory references are to the Penal Code.

1 1170.91. The People disagree. They see no need to consider legislative history and instead rely on the text of section 1170.91, subdivision (c), arguing it unambiguously excludes Harrison under an eligibility carveout that excludes anyone who has committed an offense described by section 667, subdivision (e)(2)(C)(iv), which lists so-called “super strike” offenses for purposes of the “Three Strikes” law. The People’s argument rests on a simple premise: Harrison’s 1995 conviction for violating section 273ab was a violent and serious offense for which an indeterminate life sentence was imposed. And since, as such, the offense qualifies as one described by section 667, subdivision (e)(2)(C)(iv)(VIII), Harrison is ineligible for resentencing under the unambiguous terms of section 1170.91, subdivision (c), because he has been “convicted of” a super strike. Harrison’s rejoinder, offered in reply, is that section 1170.91, subdivision (c) covers only Three Strikes offenders. He claims he “was only convicted of one felony, which itself carried an indeterminate life sentence[,]” and his “indeterminate life sentence is not the result of the Three Strikes Law in any way.” “Consequently,” he contends, “he is not rendered ineligible” by section 1170.91, subdivision (c). We agree with the Attorney General. Although, on its face, Harrison’s resentencing petition adequately pleaded resentencing eligibility, any error in failing to hold a hearing was not prejudicial because the undisputed facts shown by his record of conviction demonstrate he is ineligible for resentencing under section 1170.91 as a matter of law. I. In 1995, Harrison, then 36 years old, was convicted of one count of violating section 273ab for assaulting his four-month-old daughter, causing

2 her death. Pursuant to former section 273ab, he was sentenced to a state prison term of 15 years to life. 2 The record does not show, and the People do not contend, that Harrison had any other felony conviction prior to his section 273ab conviction. A 1995 unverified probation report Harrison submitted below states only, “The defendant does have a prior record, consisting mostly of DUI’s . . . .” In February 2024, Harrison, representing himself from state prison, filed a petition for a writ of habeas corpus (habeas petition), asserting two grounds for relief and citing section 1170.91. First, he contended he had suffered a traumatic brain injury while on duty in the United States military, which injury was not considered as a mitigation factor in his sentencing. Second, he contended he had suffered from substance abuse, specifically alcohol, from the time he enlisted in the military in 1976 until some years after his time in the service, in 1990, which abuse also was not considered as a mitigation factor in his sentencing. In April 2024, the trial court denied Harrison’s habeas petition on the ground that habeas corpus relief was not available when a plain, speedy, and adequate remedy was provided by law—in Harrison’s case, by section 1170.91. The court acknowledged Harrison had attached to his habeas petition a form petition for resentencing pursuant to section 1170.91, but ruled he was required to file it separately with the court. A few weeks later, still in April 2024, Harrison, again representing himself from state prison, filed what he styled as an “Addendum for Resentence.” He stated in its first paragraph that this filing was intended as a petition for resentencing under section 1170.91 based on health conditions

2 Section 273ab has since been amended to provide for a sentence of 25

years to life. (§ 273ab, subd. (a); Stats. 1996, ch. 460, § 2, p. 2814.)

3 due to military service (resentencing petition). He again attached, among other things, a form petition for that purpose. On this form petition, he again alleged as relevant health conditions traumatic brain injury and substance abuse and that the sentencing judge did not consider these health conditions as a factor in deciding his sentence. On April 26, 2024, without conducting a hearing on Harrison’s resentencing petition, the court denied what it characterized as Harrison’s “addendum petition for resentencing pursuant to . . . section 1170.91 (a) and (b).” The court’s brief denial order says, “The defendant has failed to state a prima facie case for the relief sought” and provides no further explanation. This timely appeal followed. II. Harrison argues we should reverse the trial court’s orders denying both his habeas and resentencing petitions because the trial court erred by failing to deem them petitions for resentencing under section 1170.91 and conduct a public hearing as required by that statute. He contends his filing of section 1170.91 form petitions as part of his habeas and resentencing petitions was sufficient to meet the statutory requirements of section 1170.91 and establish a prima facie case for relief under section 1170.91. The People contend the trial court did not err because Harrison is statutorily ineligible for resentencing relief under section 1170.91. According to them, subdivision (c), which was added in 2022 along with other amendments to section 1170.91, excludes Harrison from section 1170.91’s

4 benefits because his 1995 conviction is on a cross-referenced list of disqualifying offenses under section 667, subdivision (e)(2)(C)(iv). 3 Harrison disagrees, contending that section 1170.91, subdivision (c), by its cross reference to section 667, subdivision (e)(2)(C)(iv)—which is a creature of the Three Strikes law—excludes only those persons convicted under the Three Strikes law’s super strike provisions. For this interpretation of section 1170.91, Harrison relies on section 1170.91’s legislative history, as noted above. For the reasons explained below, we reject Harrison’s argument and agree with the People. A. Section 1170.91, subdivision (b)(1) provides, “A person currently serving a sentence for a felony conviction, whether by trial or plea, who is, or was, a member of the United States military and who may be suffering from sexual trauma, traumatic brain injury, post-traumatic stress disorder, substance abuse, or mental health problems as a result of the person’s military service may petition for a recall of sentence, before the trial court that entered the judgment of conviction in the case, to request resentencing if the circumstance of suffering from sexual trauma, traumatic brain injury, post-traumatic stress disorder, substance abuse, or mental health problems as a result of the person’s military service was not considered as a factor in

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Bluebook (online)
People v. Harrison, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-harrison-calctapp-2025.