People v. Jackson CA1/4

CourtCalifornia Court of Appeal
DecidedDecember 30, 2025
DocketA169670
StatusUnpublished

This text of People v. Jackson CA1/4 (People v. Jackson CA1/4) 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. Jackson CA1/4, (Cal. Ct. App. 2025).

Opinion

Filed 12/29/25 P. v. Jackson CA1/4 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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 FOUR

THE PEOPLE, Plaintiff and Respondent, A169670 v. RAY ANTHONY JACKSON, (Alameda County Defendant and Appellant. Super. Ct. No. H44259B)

Pursuant to Penal Code section 1172.75, the trial court recalled Ray Anthony Jackson’s sentence and resentenced him.1 At the resentencing, the court struck an invalid prison-prior enhancement as well as a gang enhancement, and it reimposed the rest of Jackson’s original sentence, including an upper term for voluntary manslaughter and an upper term for a firearm enhancement. On appeal, Jackson challenges the court’s authority to reimpose the upper term sentences based on factors in aggravation which Jackson had not admitted and had not been found true beyond a reasonable doubt by a jury. We affirm.

1 All further undesignated statutory references are to the Penal Code. I. BACKGROUND A. Procedural History In 2011, Jackson pled no contest to voluntary manslaughter (§ 192), and he admitted that he personally used a firearm during the commission of the offense (§ 12022.5, subd. (a)), that the offense was committed for the benefit of a criminal street gang (§ 186.22, subd. (b)(1)), and that he had a prior felony conviction for which he had received a term of imprisonment (§ 667.5, subd. (b)). In another case, Jackson pled no contest to unlawfully possessing ammunition (former § 12316, subd. (b)(1)2). The trial court sentenced Jackson to a total of 32 years in prison. The sentence consisted of the upper term of 11 years for voluntary manslaughter, the upper term of 10 years for the firearm enhancement, 10 years for the gang enhancement, and one year for the prior prison term enhancement. The court further sentenced Jackson to eight months for the unlawful possession of ammunition. B. Resentencing In 2023, Jackson filed a memorandum seeking to be resentenced under section 1172.75. Specifically, he asked the trial court to strike the firearm enhancement and gang enhancement in the interests of justice. In the alternative, he asked the court to impose a lesser sentence for the firearm enhancement. Subsequently, the Alameda County District Attorney requested that the trial court recall Jackson’s sentence and resentence him pursuant to section 1172.75. The People agreed that the court should strike the gang

2 In 2010, the Legislature enacted a comprehensive, non-substantive

reorganization of deadly weapon statutes, which repealed section 12316, subdivision (b)(1) and enacted the substantively identical section 30305, subdivision (a)(1). (Stats. 2010, ch. 711 §§ 4, 6.)

2 enhancement (as well as Jackson’s invalid prison-prior enhancement under section 667.5, subdivision (b), as required by section 1172.75). The People did not express an opinion whether to strike the firearm enhancement, deferring to the “court’s discretion.” At the resentencing hearing, the trial court stated it had “reviewed the probation report, the district attorney’s office letter, the defendant’s brief, the People’s brief, [and] the transcript from the [original] sentencing” and considered the relevant resentencing law and factors. The court stated that “the only issue [was] the gun enhancement under [section] 12022.5.” The court then turned to the nature and circumstances of the underlying crime and Jackson’s post-conviction conduct. It described his disciplinary record as “not impressive” due in part to two recent infractions for violence. It noted that “the crime involved great violence and threat of bodily harm, et cetera” and that his criminal history reflected crimes “of increasing seriousness.” The court found no circumstances in mitigation relating to the crime. Regarding circumstances relating to the defendant, the court acknowledged that the firearm enhancement could result in a sentence of over 20 years, but it noted that other mitigating circumstances were inapplicable because it was striking the other enhancements. Defense counsel argued that Jackson’s rehabilitative efforts reduced his risk for future violence. Counsel highlighted Jackson’s family support and spiritual growth in prison. The court accepted counsel’s oral presentation without objection but was unmoved. Accordingly, the trial court struck the gang and prison-prior term enhancements and reimposed the upper term of 11 years for voluntary manslaughter and the upper term of 10 years for the firearm enhancement,

3 for a new total term of 21 years for the manslaughter conviction. Jackson appealed. II. DISCUSSION Jackson argues that the trial court erred by reimposing the upper terms for his voluntary manslaughter conviction and the associated firearm enhancement at his resentencing. Specifically, Jackson argues that section 1170, subdivision (b) and his constitutional right to a jury trial bars the court from reimposing the upper terms based on factors in aggravation which Jackson had not admitted and had not been found true beyond a reasonable doubt by a jury. We disagree. A. Forfeiture At the threshold, we observe that Jackson failed to challenge the trial court’s authority to reimpose his upper term sentences at the resentencing hearing. In anticipation of forfeiture, Jackson maintains that his defense counsel’s failure to object on this ground amounted to a denial of his right to effective assistance of counsel. As discussed post, there is a split of authority on the merits issue, which is currently pending before the Supreme Court. (Compare People v. Brannon-Thompson (2024) 104 Cal.App.5th 455, 466–467 (Brannon- Thompson) [holding that the People were not required to prove aggravating factors beyond reasonable doubt at resentencing if defendant was originally sentenced to upper term]; People v. Gonzalez (2024) 107 Cal.App.5th 312, 329–330 [holding that trial court erred in re-imposing upper term based on factors not stipulated to by defendant nor proved beyond a reasonable doubt] (Gonzalez); see also People v. Eaton, 2025 Cal.App.Unpub. 1567 (Mar. 14, 2025, C096853) [nonpub. opn.], review granted May 14, 2025, S289903 [presenting the question over which Brannon-Thompson and Gonzalez split].)

4 The resolution to this live issue will inform whether competent counsel should have raised an objection to the reimposition of the upper term sentences at the resentencing hearing. Therefore, to forestall Jackson’s ineffective assistance of counsel claim, we do not apply forfeiture. Instead, we exercise our discretion to consider the merits and therefore need not address Jackson’s alternative claim for ineffective assistance of counsel. (Gonzalez, supra, 107 Cal.App.5th at pp. 326–327.) B. Standard of Review We review the trial court’s sentencing decision for abuse of discretion and will not set it aside unless it is so irrational or arbitrary that no reasonable person could reach the same result. (See People v. Carmony (2004) 33 Cal.4th 367, 376–377.) However, we review legal issues, such as statutory or constitutional interpretation, de novo. (California Advocates for Nursing Home Reform v. Smith (2019) 38 Cal.App.5th 838, 864.) When construing a statute, our fundamental task is to ascertain the Legislature’s intent and effectuate the law’s purpose. (Stone v. Alameda Health System (2024) 16 Cal.5th 1040, 1052.) To determine legislative intent, we principally look to the statute’s actual words.

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Related

Apprendi v. New Jersey
530 U.S. 466 (Supreme Court, 2000)
People v. Carmony
92 P.3d 369 (California Supreme Court, 2004)
Cal. Advocates for Nursing Home Reform v. Smith
251 Cal. Rptr. 3d 636 (California Court of Appeals, 5th District, 2019)
People v. Padilla
509 P.3d 975 (California Supreme Court, 2022)

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People v. Jackson CA1/4, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-jackson-ca14-calctapp-2025.