People v. McDowell CA2/6

CourtCalifornia Court of Appeal
DecidedMay 19, 2026
DocketB342468
StatusUnpublished

This text of People v. McDowell CA2/6 (People v. McDowell CA2/6) 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. McDowell CA2/6, (Cal. Ct. App. 2026).

Opinion

Filed 5/19/26 P. v. McDowell CA2/6 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

SECOND APPELLATE DISTRICT

DIVISION SIX

THE PEOPLE, 2d Crim. No. B342468 (Super. Ct. No. 2023023183) Plaintiff and Respondent, (Ventura County)

v.

WILLAM SCOTT MCDOWELL,

Defendant and Appellant.

Willam Scott McDowell appeals a judgment following his convictions for two counts of criminal threats (Pen. Code, § 422, subd. (a); counts 1 and 3) and possession of a controlled substance while armed with a firearm (Health & Saf. Code, § 11370.1, subd. (a); count 4). As to counts 1 and 3, the jury found true that McDowell personally used a firearm (Pen. Code, § 12022.5, subd. (a)(1)). The trial court placed McDowell on three years’ probation. McDowell contends the trial court erred by not instructing the jury on the lesser included offenses of simple possession of methamphetamine for count 4 and attempted criminal threats for count 1. We affirm. FACTUAL AND PROCEDURAL HISTORY In September 2023, Martin Hahn was renting a home at property located in Santa Paula. McDowell is the son of the owners of this property. He was living in one house on the property, his parents lived in “the main house,” and Hahn lived in another house on the property. Hahn came home from work one evening. He got out of his car, and could hear McDowell on his property located up on the hill “doing a lot of yelling.” McDowell was “a few hundred feet” away from Hahn. He was yelling for 15 to 20 minutes. Hahn did not know what McDowell was yelling about and decided to do some work on the outside of his house in the driveway. McDowell came “down the hill” and continued to yell. He was on a “dirt bike” as he approached Hahn’s house. Hahn became concerned because McDowell was swearing and yelling Hahn’s name. McDowell told Hahn that he “need[ed] to F’ing go,” “needed to fucking get out of here,” and that he knew “what you’re fucking up to.” Neighbors described McDowell as “very agitated, very upset, not his normal self,” “angry,” and “a bit out of control.” Hahn then approached the property line separating his and McDowell’s houses. He tried to talk to McDowell for “20 or 30 seconds.” Hahn asked him, “Why are you so upset?” McDowell said he “knows what” Hahn is “up to” and told him that he “needed to leave.” McDowell said you “need to fucking get out of here.” Hahn had “no idea what he was talking about.” McDowell then lifted his shirt, put his hand on a “revolver” located inside a holster, and “pulled it out just a little bit.” Hahn

2 “recognized it was a revolver” within “less than a second.” McDowell’s hand was on the “grip” and his “body language was aggressive.” Hahn then “quickly” left in a lateral direction “to be a harder target . . . because [he] didn’t want to get shot.” Hahn was “frightened,” retreated to his house, and told his neighbors to “stay inside.” Once inside his house, but still concerned for his safety, Hahn “grabbed a firearm,” checked to make sure McDowell was gone, and went down to the main house to speak to McDowell’s parents. He testified, “I thought maybe he might pursue me because he seemed to be very agitated at me specifically because he was using my name and telling me I should leave and he had a firearm.” While speaking to McDowell’s mother, Hahn “heard a gunshot.” Shortly thereafter, Hahn called 911. At the preliminary hearing, Hahn testified that he “responded out of . . . action, not out of fear.” When asked why he said that when he testified at trial, Hahn responded, “I said that because I think that’s what men say initially. I also said that because part of it is training. You respond. You . . . act and you move. But in hindsight, I thought about it, why did I go arm myself? Why did I do that? And I did that because I was fearful.” Sheriff deputy Kenneth Ledesma responded to a report of a person “shooting a firearm into the air in a rural area of Santa Paula.” A team of officers spotted McDowell on a hill. They asked him to come down “from the hill and surrender.” As the officers approached McDowell, they noticed that he possessed a firearm and was “acting bizarre.” McDowell dismounted from his “motorcycle” and surrendered. He put the firearm down, “got on the ground,” and was placed in handcuffs. Officers found a methamphetamine pipe on his person. Ledesma believed the

3 pipe contained a usable amount of methamphetamine. But the substance inside the pipe had not been tested. Another officer seized McDowell’s firearm, confirmed that it was operable, and verified that it was loaded with ammunition and contained one spent shell casing. McDowell was wearing overalls when he was initially detained. Underneath the overalls he wore pants. He later removed the overalls. McDowell was transported to the Ventura County jail. Deputies searched him there and found a bag of methamphetamine in his left pants pocket. McDowell told the deputies, “I didn’t know I had that.” He said, “I put these pants on outside my house. That’s a motherfucker. God damn it.” The jury convicted McDowell of the charged offenses of criminal threats against Hahn (Pen. Code, § 422, subd. (a)), criminal threats against another victim (ibid.), and possession of a controlled substance while armed with a firearm (Health & Saf. Code, § 11370.1, subd. (a)).1 The jury also found true accompanying personal firearm use allegations on counts 1 and 3. The jury was not instructed on any lesser included offenses. DISCUSSION Lesser included offense of simple possession McDowell contends the trial court erred when it failed to instruct the jury on simple possession of methamphetamine because there was no evidence he possessed a firearm and methamphetamine at the same time. We are not persuaded. “A trial court has a sua sponte duty to instruct the jury on any uncharged lesser offense that is necessarily included in a

1 After the prosecution’s case in chief, the trial court

partially granted the defense motion and dismissed counts 2 and 5. (Pen. Code, § 1118.1.)

4 charged offense if there is substantial evidence from which the jury could reasonably conclude that the defendant committed the lesser included offense but not the charged offense.” (People v. Lopez (2020) 9 Cal.5th 254, 269.) But a trial court is not required to instruct on a lesser included offense “in the absence of substantial evidence” that the defendant committed only the lesser offense. (People v. Benavides (2005) 35 Cal.4th 69, 102.) Our instructional error review is de novo. (People v. Nelson (2016) 1 Cal.5th 513, 538.) Here, McDowell was charged with possessing methamphetamine while armed with a firearm. (Health & Saf. Code § 11370.1, subd. (a).) The statute requires proof that the defendant simultaneously possessed the controlled substance “while armed with” the firearm. (People v. Allen (2023) 96 Cal.App.5th 573, 580–581.) The Attorney General correctly concedes that here, simple possession of methamphetamine (Health & Saf. Code, § 11377, subd. (a)) is “a lesser included offense of Health and Safety Code section 11370.1, subdivision (a).” “ ‘[A] lesser offense is necessarily included in a greater offense if . . . the facts actually alleged in the accusatory pleading, include all the elements of the lesser offense, such that the greater cannot be committed without also committing the lesser.’ ” (People v.

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People v. McDowell CA2/6, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-mcdowell-ca26-calctapp-2026.