People v. Ruiz CA4/2

CourtCalifornia Court of Appeal
DecidedSeptember 15, 2023
DocketE079870
StatusUnpublished

This text of People v. Ruiz CA4/2 (People v. Ruiz 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. Ruiz CA4/2, (Cal. Ct. App. 2023).

Opinion

Filed 9/15/23 P. v. Ruiz 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NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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, E079870

v. (Super.Ct.No. FWV036076)

REYNALDO RUIZ, OPINION

Defendant and Appellant.

APPEAL from the Superior Court of San Bernardino County. Michael R.

Libutti, Judge. Affirmed.

Carl Fabian, 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, Arlene A. Sevidal, Lynne M.

McGinnis and James M. Toohey, Deputy Attorney Generals, for Plaintiff and

Respondent.

1 In February 2007, a jury found defendant and appellant Reynaldo Ruiz guilty of

attempted murder (Pen. Code,1 §§ 187, subd. (a), 664, subd. (a)); robbery (§ 211); and

participating in a criminal street gang (§ 186.22, subd. (a)). The jury found true the

special circumstance that the attempted murder was committed willfully, deliberately,

and with premeditation. (§§ 189, 664, subd. (a).) The jury also found various firearm

and gang enhancements true. The jury found that defendant’s codefendant, Marco

Antonio Ruiz (Brother), personally discharged a firearm causing injury to the victim.

The trial court sentenced defendant to prison for life with the possibility of parole plus a

consecutive term of 25 years to life (§ 12022.53, subds. (d) & (e)(1)).2

In January 2022, defendant petitioned the trial court for resentencing, arguing

that he was convicted of attempted murder under the natural and probable consequences

doctrine, which is no longer a recognized crime. (Former § 1170.95, subd. (a).)3 The

trial court found that defendant failed to establish a prima facie case for relief and

denied the petition. Defendant contends the trial court erred by finding he did not make

a prima facie case. We affirm.

1 All further statutory references are to the Penal Code unless otherwise indicated.

2 The sentencing minute order incorrectly calculates defendant’s total sentence as life with the possibility of parole—mistakenly omitting the consecutive term of 25 years to life. However, the abstract of judgment is accurate.

3 Section 1170.95 has been renumbered section 1172.6. We cite section 1170.95 because that was the statute in effect at the time defendant filed his petition in the trial court.

2 FACTUAL AND PROCEDURAL HISTORY

A. DEFENDANT’S CRIMES

On Halloween night 2005, the victim and his friend (Friend) were in a liquor

store parking lot when defendant; Brother, who is defendant’s younger brother; and two

of their gang associates arrived in the parking lot. (People v. Ruiz (May 15, 2009,

E042886) [nonpub. opn.] [2009 WL 1362283, *2-3, 9].) Defendant asked the victim

and Friend where they were from and ultimately robbed the victim and Friend. (Id. at p.

*2.) As the victim and Friend ran toward the liquor store after being robbed, Brother

shot the victim in his back. (Id. at p. *3.)

B. PROSECUTOR’S CLOSING ARGUMENT

During closing arguments to the jury, the prosecutor argued, “Why do you shoot

someone who’s running away from you? Why do you shoot someone who you’ve

already robbed? Why? To eliminate witnesses. Gang members don’t shoot to injure.

Gang members shoot to kill. And that’s exactly what happened in this case.” The

prosecutor continued, “Why would [Brother] shoot a guy that they’ve already robbed?

He’s running away. He’s going back into the liquor store, right? They’ve already

robbed him. . . . [¶] . . . Because they’re trying to kill him.”

C. DIRECT APPEAL

In defendant’s direct appeal from his convictions, he asserted that there was not

substantial evidence to support the intent to kill element of his attempted murder

conviction. (People v. Ruiz, supra, [2009 WL 1362283, *8].) This court rejected that

contention. (Id. at p. *9.) In a footnote to that analysis, this court wrote, “The

3 prosecution did not rely upon the natural and probable consequences doctrine in

charging [defendant] or [Brother] with the attempted murder. Specifically, the

prosecution did not allege that [Brother] or [defendant] intended to commit some other

target crime of which the attempted murder was a natural and probable consequence.

Instead, the prosecution proceeded upon the theory that the attempted murder was itself

the intended crime.” (Id. at p. *8, fn. 3.)

D. DEFENDANT’S PETITION

Defendant’s petition for resentencing consisted of marking the boxes on a form

indicating that he met the statutory requirements for relief and attaching his abstract of

judgment to the form.

E. PEOPLE’S OPPOSITION

In opposing defendant’s petition, the People asserted that the laws had changed

to no longer permit an attempted murder conviction under a natural and probable

consequences theory, but the prosecution did not rely upon a natural and probable

consequences theory in defendant’s case. Rather, the prosecution presented a theory of

direct aiding and abetting, which remains a valid theory of attempted murder.

F. DEFENDANT’S REPLY

In defendant’s reply, he contended the jury did not explicitly find that he

intended to kill the victim because the jury was inadequately instructed on aiding and

abetting. The trial court denied defendant’s petition.

4 DISCUSSION

Defendant contends the trial court erred by finding his petition did not set forth a

prima facie case for relief.

The resentencing statute provided, “A person convicted of . . . attempted murder

under the natural and probable consequences doctrine . . . may file a petition with the

court that sentenced the petitioner to have the petitioner’s . . . attempted murder . . .

conviction vacated and to be resentenced on any remaining counts.” (Former

§ 1170.95, subd. (a).)

The natural and probable consequences doctrine refers to a situation in which

“ ‘a person who knowingly aided and abetted a crime, the natural and probable

consequence of which was murder or attempted murder, could be convicted of not only

the target crime but also of the resulting murder or attempted murder. [Citations.]

“This was true irrespective of whether the defendant harbored malice aforethought.

Liability was imposed ‘ “for the criminal harms [the defendant] . . . naturally, probably,

and foreseeably put in motion.” ’ ” ’ ” (People v. Lee (2020) 49 Cal.App.5th 254, 261.)

The natural and probable consequences doctrine is no longer a valid theory for an

attempted murder conviction. (People v. Offley (2020) 48 Cal.App.5th 588, 595.)

However, direct aiding and abetting remains a valid theory for attempted murder. (Id. at

p. 595-596.) Direct aiding and abetting means the defendant had the mental state

required for murder, e.g., intent to kill. (People v. McCoy (2001) 25 Cal.4th 1111,

1117-1118.)

5 When determining if a defendant is entitled to relief under former section

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Related

People v. McCoy
24 P.3d 1210 (California Supreme Court, 2001)
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People v. Johnson
364 P.3d 359 (California Supreme Court, 2016)
Persons Coming Under the Juvenile Court Law. San Bernardino Cnty. Children v. B.F. (In re J.F.)
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Bluebook (online)
People v. Ruiz CA4/2, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-ruiz-ca42-calctapp-2023.