People v. Henderson CA1/3

California Court of Appeal·Decided August 20, 2026·No. A167694·Unpublished

Opinion

Filed 8/20/26 P. v. Henderson CA1/3 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

FIRST APPELLATE DISTRICT

DIVISION THREE

THE PEOPLE, Plaintiff and Respondent, A167694, A168303 v.

(Contra Costa County

ANTHONY FERRANTE Super. Ct. No. 042200199) HENDERSON, Defendant and Appellant.

A jury convicted Anthony Ferrante Henderson of various offenses, including attempted murder and firearm possession, resulting in an aggregate sentence of 50 years to life. On appeal, he contends we must reverse his convictions due to evidentiary errors. He also argues the trial court erred by imposing two concurrent sentences for firearm convictions based on the same, single act of possessing a firearm; the Attorney General concedes this point. We remand for resentencing but otherwise affirm.

BACKGROUND

Late in the evening on April 24, 2022, a man was driving his truck home. A city surveillance camera recorded Lewis Parker driving a black sedan and involved in a road rage incident with the man in the truck. Afterward, the man pulled to the side of the road across from a church and activated his hazard lights. Approximately 90 seconds later, Parker arrived

with a light-colored four-door car, which slowed down near the man’s truck. Two people exited the light-colored car and fired over 20 shots at the man and his truck — he was shot six times, including twice near his heart, twice in his stomach, and once in his right arm. Immediately after the shooting, the man accelerated out of the area, passing the shooter’s vehicle. Officers discovered the man, who was conscious but not coherent, a few miles away. They recovered two different caliber bullet casings — .40 and .223 — from the parking lot near the church. There were also 10 bullet holes in the exterior of a nearby house.

Six days after the shooting, officers stopped a gold Honda sedan with an inoperable brake light, improperly tinted windows, and expired registration. Henderson was driving with the car’s registered owner, Consuela Lewis, and others in the car. During a search of the car, officers discovered an unregistered semiautomatic Glock handgun loaded with .40- caliber rounds tucked inside the felt lining just above the driver’s seat. The officer who discovered the gun recalled viewing an Instagram video associated with Henderson that appeared to contain the same gun. The officer regularly monitored Instagram accounts, including Henderson’s, since individuals sometimes post content related to criminal activity. Lewis immediately stated the gun belonged to her. Officers nonetheless arrested Henderson.

Henderson’s DNA was later found on the gun along with three other unidentified contributors. A firearms examiner concluded that the gun fired some of the casings recovered from the scene of the shooting. And cell phone records linked Henderson’s cell phone location to Parker’s associate, Michael Holbert, Jr., who Parker called just prior to the shooting and who was

subsequently captured on surveillance camera footage leaving his home located a little over one mile from the scene.

The district attorney charged Henderson with attempted murder (Pen.

Code, §§ 187, subd. (a), 664, count 1, undesignated statutory references are to this code); conspiracy to commit murder (§ 182, subd. (a)(1), count 2); assault with a semiautomatic firearm (§ 245, subd. (b), count 3); shooting at an occupied motor vehicle (§ 246, count 4); shooting at an inhabited dwelling (§ 246, count 5); possession of a firearm by a felon (§ 29800, subd. (a)(1), count 6); carrying a loaded firearm with a prior conviction (§ 25850, subd. (a), count 7); and carrying a concealed firearm in a vehicle with a prior conviction (§ 25400, subds. (a)(1), (c)(1), count 8). The complaint also alleged Henderson personally and intentionally discharged a firearm causing great bodily injury for counts 1 and 4 (§ 12022.53, subd. (d)), and that he personally used a firearm for count 3 (§ 12022.5, subd. (a)).

About one month after Henderson’s arrest, the trial court temporarily released him on a four-hour funeral pass. He did not return. Officers located him six days later with Lewis. They arrested him and seized Lewis’s phone, which contained messages exchanged with an individual named Maddie. Some of the messages were directed to Henderson, including a screenshot of an Instagram post claiming he was a confidential informant. Henderson responded, “everybody in jail think ima [sic] rat” — a snitch — and noted someone would stab him if he returned. When asked why people believed he was a snitch, Henderson said, “What they saying I’m telling on is sun [sic] I did” — “A murder [¶] [t]hat I did.” “It was a driver n a shooter I was the shooter they got the driver cause his car and they saying I’m telling how I’m telling if I’m the only shooter what I’m do tell on my self.” He said this murder occurred two weeks before he was arrested, “Two weeks for I went

down.” The driver identified in the message was Parker, who officers arrested.

Before trial, Henderson moved to admit Lewis’s statements claiming ownership of the gun as a statement against her penal interest. He also sought to exclude the messages to Maddie because they were not admissions regarding the charged offenses and were thus inadmissible character evidence. The trial court ultimately admitted the text messages but excluded Lewis’s statements.

A jury found Henderson guilty of all charges and enhancements. The trial court sentenced him to 50 years to life in prison, including the middle term of four years for being a felon in possession of a firearm (count 6), and a concurrent sentence for both carrying a loaded firearm while having a prior conviction (count 7) and having a concealed firearm in a vehicle (count 8).

DISCUSSION

I.

Henderson contends Lewis’s statements claiming ownership of the gun were statements against her penal interest and the trial court abused its discretion by excluding them. We disagree.

Hearsay — “evidence of a statement that was made other than by a witness while testifying at the hearing and that is offered to prove the truth of the matter stated” — is inadmissible unless it qualifies under an exception, such as a statement made against the declarant’s penal interests. (Evid. Code, §§ 1200, subds. (a)–(b), 1230.) To qualify under this exception, the statement when made must be “so far contrary to the declarant’s pecuniary or proprietary interest, or so far subjected” her to “the risk of civil or criminal liability,” that a reasonable person in that position would not have made the statement unless she believed it to be true. (Evid. Code, § 1230.) The

proponent must demonstrate “that the declarant is unavailable, that the declaration was against the declarant’s penal interest when made and that the declaration was sufficiently reliable to warrant admission despite its hearsay character.” (People v. Duarte (2000) 24 Cal.4th 603, 610–611.) We review whether a party has established the foundational facts for a hearsay exception for substantial evidence but review the ultimate ruling for an abuse of discretion — that is, whether the ruling was arbitrary, capricious, or patently absurd. (People v. DeHoyos (2013) 57 Cal.4th 79, 132.)

Lewis was subpoenaed to testify at a hearing to determine the admissibility of her statements. She initially refused the assistance of counsel but relented after the trial court explained that her statements could result in admitting to a criminal offense. She subsequently invoked her Fifth Amendment right to not incriminate herself, refused to answer questions regarding her prior statements, and the court accordingly found her unavailable to testify.

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