People v. Hunter CA4/2

CourtCalifornia Court of Appeal
DecidedMarch 22, 2022
DocketE073825A
StatusUnpublished

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

Opinion

Filed 3/22/22 P. v. Hunter CA4/2 Opinion following transfer from Supreme Court NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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, E073825

v. (Super.Ct.No. RIF1105356)

BRIUANA LASHANAE HUNTER, OPINION

Defendant and Appellant.

APPEAL from the Superior Court of Riverside County. John D. Molloy, Judge.

Reversed and remanded with directions.

Mark D. Johnson, under appointment by the Court of Appeal, for Defendant and

Appellant.

Rob Bonta and Xavier Becerra, Attorney General, Lance E. Winters, Chief

Assistant Attorney General, Julie L. Garland, Assistant Attorney General, Steve Oetting,

Acting Assistant Attorney General, Charles C. Ragland and James H. Flaherty III,

Deputy Attorneys General, for Plaintiff and Respondent.

1 I

INTRODUCTION

Originally charged with first degree murder along with her mother, in 2013

defendant and appellant Briuana Lashanae Hunter ultimately pleaded guilty to one count

of voluntary manslaughter (Pen. Code, 1 § 192, subd. (a)) and three counts of attempted

murder (§§ 664 & 187, subd. (a)). Defendant also admitted that a principal used a

firearm (§ 12022, subd. (a)(1)) during the commission of the voluntary manslaughter.

In 2019, defendant filed a petition for resentencing pursuant to section 1170.95.

The trial court denied the petition finding voluntary manslaughter and attempted murder

convictions were ineligible for relief under the statute, which was the correct result at the

time, and in a prior nonpublished opinion, People v. Hunter (Oct. 19, 2020, E073825)

(Hunter I), we affirmed the trial court’s order. The Legislature, however, since has

passed and the Governor has signed Senate Bill No. 775 (2020-2021 Reg. Sess.) (Senate

Bill 775), which makes clear that persons convicted of attempted murder and voluntary

manslaughter can seek resentencing relief. (Stats. 2021, ch. 551, § 2.)

Following the issuance of our prior opinion upholding the trial court’s order,

defendant filed a petition for review in the California Supreme Court (S265569). The

court granted review, and on December 29, 2021, remanded the matter to us with

directions to vacate our prior decision and reconsider the cause in light of Senate

1 All future statutory references are to the Penal Code unless otherwise stated.

2 Bill 775. We vacated our decision on January 7, 2022, and allowed the parties to file

supplemental briefs.

In supplemental briefing, defendant contends that she is eligible for resentencing

under section 1170.95, as amended by Senate Bill 775, and thus the matter should be

remanded for the superior court to reconsider her petition. The People argue that remand

is not necessary because defendant’s “admission of the factual basis for her guilty plea,

unequivocally demonstrates beyond a reasonable doubt that [defendant] was a direct

aider and abettor to the killing and that she acted with malice aforethought.”

Alternatively, the People assert that if the record does not conclusively establish

ineligibility for relief as a matter of law, we should remand with directions to the trial

court to permit the parties to brief whether defendant has established a prima facie

basis for resentencing relief and, if so, to hold further proceedings consistent with

section 1170.95, subdivision (c).

Because section 1170.95, as amended by Senate Bill 775, will provide

resentencing relief for individuals charged with attempted murder and voluntary

manslaughter under certain circumstances, and because the record does not conclusively

establish ineligibility as a matter of law, we will reverse the trial court’s order and

remand the matter for the court to reconsider defendant’s petition in the first instance.

3 II

BACKGROUND

In 2013, defendant pleaded guilty to one count of voluntary manslaughter (§ 192,

subd. (a)) and three counts of attempted murder (§§ 664 & 187, subd. (a)). Defendant

also admitted that a principal used a firearm (§ 12022, subd. (a)(1)) during the

commission of the voluntary manslaughter. In return, the remaining charges and

enhancement allegations were dismissed, and defendant was sentenced to a total term of

18 years in prison. 2

While defendant was serving her 18-year prison term, the Legislature enacted

Senate Bill No. 1437 (2017-2018 Reg. Sess.) (Stats. 2018, ch. 1015, §§ 1-4) (Senate

Bill 1437), which amended the law governing murder liability under the felony murder

and natural and probable consequences theories and provided a new procedure under

section 1170.95 for eligible defendants to petition for recall and resentencing.

On August 29, 2019, defendant filed a petition to vacate her voluntary

manslaughter and attempted murder convictions and for resentencing pursuant to

section 1170.95.

2 Defendant was originally sentenced to 18 years four months. However, pursuant to a letter submitted by the California Department of Corrections and Rehabilitation, in July 2018, the trial court amended defendant’s sentence to a total term of 18 years. The court stayed the one-year term for the gun enhancement and ordered an amended abstract of judgment. The amended abstract of judgment incorrectly indicates defendant’s total sentence of 19 years and fails to note the firearm enhancement was stayed.

4 On September 13, 2019, the trial court summarily denied the petition without

prejudice, finding defendant had not established a prima facie case for resentencing, as

she was not convicted of murder. Defendant timely appealed from the trial court’s order.

In October 2020, this court issued a nonpublished opinion affirming the trial

court’s denial of defendant’s petition, concluding attempted murder and voluntary

manslaughter were ineligible for relief as a matter of law under section 1170.95, because

the plain language of the statute referred to a “murder conviction” but not attempted

murder or voluntary manslaughter. (Hunter I, supra, E073825, at pp. 3-18.) Defendant

subsequently filed a petition for review with the Supreme Court (S265569).

While this matter was pending, the Legislature enacted Senate Bill 775, which

amended section 1170.95 to clarify that persons convicted of manslaughter and attempted

murder may be eligible for resentencing under that section. As amended, section 1170.95

expressly applies to persons “convicted of . . . attempted murder under the natural and

probable consequences doctrine, or manslaughter.” (§ 1170.95, subd. (a).)

On December 29, 2021, S265569, the Supreme Court transferred defendant’s case

back to this court with directions to vacate our prior decision and reconsider the cause in

light of Senate Bill 775. We vacated our prior opinion and permitted the parties to file

5 III

DISCUSSION

Effective January 1, 2019, the Legislature passed Senate Bill 1437 (2017-2018

Reg. Sess.) “to amend the felony murder rule and the natural and probable consequences

doctrine . . . to ensure that murder liability is not imposed on a person who is not the

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Related

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