People v. Reed CA4/2

CourtCalifornia Court of Appeal
DecidedJanuary 13, 2025
DocketE083073
StatusUnpublished

This text of People v. Reed CA4/2 (People v. Reed 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. Reed CA4/2, (Cal. Ct. App. 2025).

Opinion

Filed 1/13/25 P. v. Reed CA4/2

NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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, E083073

v. (Super.Ct.No. RIF1300690)

GUY DAVID REED, OPINION

Defendant and Appellant.

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

Affirmed.

Brad J. Poore, under appointment by the Court of Appeal, for Defendant and

Appellant.

Rob Bonta, Attorney General, Lance E. Winters, Chief Assistant Attorney

General, Charles C. Ragland, Assistant Attorney General, A. Natasha Cortina and Alan

L. Amann, Deputy Attorneys General, for Plaintiff and Respondent.

1 Guy David Reed appeals from the trial court’s order denying him relief under

Penal Code section 1172.75. (Unlabeled statutory references are to the Penal Code.)

Reed argues that section 1172.75 applies to defendants who had their punishment struck

on a prior prison term sentencing enhancement. We disagree and affirm.

BACKGROUND

In 2013, a jury convicted Reed of assault with force likely to produce great bodily

injury (§ 245, subd. (a)(4)), battery causing serious bodily injury (§ 243, subd. (d)), and

criminal threats (§ 422). The jury also found that Reed inflicted great bodily injury

(§ 12022.7, subd. (a)). Reed admitted that he had three prior prison terms (§ 667.5, subd.

(b)), one prior serious felony conviction (§ 667, subd. (a)), and one prior serious and

violent felony strike conviction (§§ 667, subds. (c) & (e)(1), 1170.12, subd. (c)(1)). The

trial court sentenced Reed to 16 years in state prison and imposed the three prior prison

term enhancements but struck the punishment for each of them.

In 2022, the trial court received notice from the California Department of

Corrections and Rehabilitation (CDCR) that Reed was serving a term for a judgment that

included prior prison term enhancements that are now invalid under section 1172.75.1 In

December 2023, the court held a hearing and declined to resentence Reed, finding that he

was not eligible for resentencing under section 1172.75.

1 Reed filed a request for judicial notice on July 17, 2024. We grant that request and take judicial notice of the declarations of Aimee Vierra and David McKinney filed in case No. E082642, and we augment the record in this case to include the CDCR list dated June 16, 2022, listing individuals eligible for relief under section 1172.75. Reed is listed on page 27 of that document. 2 DISCUSSION

Reed argues that section 1172.75 applies to defendants who had the punishment

struck on their prior prison term enhancements. We disagree.

Section 1172.75, subdivision (a), provides that “[a]ny sentence enhancement that

was imposed prior to January 1, 2020, pursuant to subdivision (b) of Section 667.5,

except for any enhancement imposed for a prior conviction for a sexually violent offense

. . . is legally invalid.” Section 1172.75, subdivision (b), requires the Secretary of CDCR

and the administrators for each county jail to “identify those persons in their custody

currently serving a term for a judgment that includes an enhancement described in

subdivision (a)” and to provide certain information about those individuals “to the

sentencing court that imposed the enhancement.” Upon receiving that information, the

trial court “shall recall the sentence and resentence the defendant” if the court

“determines that the current judgment includes an enhancement described in subdivision

(a).” (§ 1172.75, subd. (c).) If the court determines that the individual’s judgment

includes such an enhancement, the defendant’s resentencing “shall result in a lesser

sentence than the one originally imposed as a result of the elimination of the repealed

enhancement, unless the court finds by clear and convincing evidence that imposing a

lesser sentence would endanger public safety.” (§ 1172.75, subd. (d)(1).)

The issue presented in this case—whether section 1172.75 applies to prior prison

term enhancements that were imposed but as to which the punishment was struck—is

closely related to an issue on which our appellate courts are currently split, namely,

3 whether section 1172.75 applies to prior prison term enhancements that were imposed but

stayed. People v. Rhodius (2023) 97 Cal.App.5th 38, review granted February 21, 2024,

S283169 (Rhodius), held that “imposed” in subdivision (a) of section 1172.75 must be

interpreted as shorthand for “imposed and executed” in order to make sense of the

requirement in section 1172.75, subdivision (d)(1), that resentencing must result in “a

lesser sentence than the one originally imposed as a result of the elimination of the

repealed enhancement.” (Rhodius, at p. 43.) Reasoning that “[t]he only way for the

repealed enhancement to have increased the length of a sentence is for the enhancement

to have been imposed and executed,” Rhodius concluded that if section 1172.75 applied

to stayed prior prison term enhancements, then a resentencing court faced with such an

enhancement would be required to “arbitrarily lower” the defendant’s sentence to comply

with the “lesser sentence” requirement. (Rhodius, at p. 44.) Because the Legislature

presumably did not intend such an outcome, Rhodius held that section 1172.75 must be

interpreted to apply only to prior prison term enhancements that were imposed and

executed. (Rhodius, at p. 44.)

The rest of the published appellate decisions to consider the issue have concluded

that section 1172.75 does apply to prior prison term enhancements that were imposed but

stayed. (People v. Renteria (2023) 96 Cal.App.5th 1276; People v. Christianson (2023)

97 Cal.App.5th 300, review granted Feb. 21, 2024, S283189 (Christianson); People v.

Saldana (2023) 97 Cal.App.5th 1270, review granted Mar. 12, 2024, S283547 (Saldana);

People v. Mayberry (2024) 102 Cal.App.5th 665, review granted Aug. 14, 2024, S285853

4 (Mayberry).) Christianson, Saldana, and Mayberry reasoned that Rhodius’s concern

about applying section 1172.75 to stayed enhancements was unfounded, because striking

a stayed enhancement does result in a “lesser” sentence within the meaning of section

1172.75, subdivision (d)(1). As Christianson explained, a stayed enhancement carries

“the potential for an increased sentence,” because “the trial court retains the ability to lift

the stay and impose the term under certain circumstance[s], such as if an alternately

imposed term is invalidated.” (Christianson, at p. 312.) Striking a stayed enhancement

reduces the defendant’s sentence, because it eliminates the risk that the enhancement will

be executed in the future. (Ibid.; see also Saldana, at p. 1278; Mayberry, at pp. 674-675

[“Imposed-but-stayed prior prison term enhancements carry the possibility of execution,”

and striking them “eliminates their impact”].) Resentencing courts thus would not be

required to arbitrarily lower a sentence that included a stayed prior prison term

enhancement, because striking the stayed enhancement is sufficient to satisfy the “lesser

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People v. Reed CA4/2, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-reed-ca42-calctapp-2025.