People v. Thomas CA2/5

CourtCalifornia Court of Appeal
DecidedMarch 19, 2026
DocketB343235
StatusUnpublished

This text of People v. Thomas CA2/5 (People v. Thomas CA2/5) 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. Thomas CA2/5, (Cal. Ct. App. 2026).

Opinion

Filed 3/19/26 P. v. Thomas CA2/5 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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 FIVE

THE PEOPLE, B343235

Plaintiff and Respondent, (Los Angeles County Super. Ct. No. v. SA008528)

KEVIN ODELL THOMAS,

Defendant and Appellant.

APPEAL from an order of the Superior Court of Los Angeles County, William L. Sadler, Judge. Affirmed. William L. Heyman, under appointment by the Court of Appeal, for Defendant and Appellant. Rob Bonta, Attorney General, Charles C. Ragland, Chief Assistant Attorney General, Susan Sullivan Pithey, Senior Assistant Attorney General, Noah P. Hill, Supervising Deputy Attorney General, Deepti Vaadyala, Deputy Attorney General, for Plaintiff and Respondent. A jury convicted Kevin Odell Thomas (defendant) of special circumstance murder and second degree robbery, and the trial court sentenced him to life without the possibility of parole (LWOP). Many years later, he requested a People v. Franklin (2016) 63 Cal.4th 261 hearing to preserve evidence for a future youth offender parole hearing. The trial court denied that request because defendant is serving an LWOP sentence that makes him statutorily ineligible for a Franklin hearing. We are asked to decide whether the governing youth offender parole statute that makes him ineligible for a Franklin hearing violates constitutional equal protection or cruel or unusual punishment guarantees.

I. BACKGROUND A. Defendant’s Conviction and Sentencing On the morning of Friday, November 8, 1991, Donald Lee (Lee), who owned a check cashing business, withdrew $64,000 in cash from a branch of Wells Fargo Bank located on South Sepulveda Boulevard in Los Angeles. Moments after Lee left the bank through its rear door, defendant accosted him. Matters escalated quickly with both men drawing guns from their waistbands and opening fire at each other. Lee was hit multiple times and fell to the ground, fatally wounded. Defendant, also wounded, grabbed the bag containing most of Lee’s cash and fled the scene with two accomplices. At the time, defendant was 19 years old.

2 The Los Angeles District Attorney charged defendant by information with murder (Pen. Code,1 § 187, subd. (a)) and second degree robbery (§ 211). The information also alleged defendant committed the murder while engaged in the commission of a robbery (§ 190.2, subd. (a)(17)), personally used a handgun (§ 12022.5, subd. (a)), and was a principal armed with a handgun (§ 12022, subd. (a)(1)). A jury found defendant guilty of both crimes and found true the special circumstance and firearm allegations. The trial court sentenced defendant to LWOP for the special circumstance first degree murder, plus five additional years for the personal use firearm enhancement, and stayed the sentence for the principal- armed enhancement. The court also stayed a six-year sentence on the robbery conviction. On direct appeal, a different panel of this court affirmed the judgment. (People v. Thomas (Sept. 28, 1995, B083574) [nonpub. opn.].)

B. Defendant’s Franklin Requests Many years later, in 2019, defendant moved for a Franklin hearing. The trial court took the matter off calendar after defendant’s deputy public defender advised that her client was not eligible for relief under Franklin.2 In March 2023, defendant filed a form motion for a Franklin hearing and appointment of counsel. In his motion, defendant argued the exclusion of offenders aged 18 to 25

1 Undesignated statutory references that follow are to the Penal Code. 2 This proceeding involved a different bench officer than the one whose ruling is the subject of this appeal.

3 sentenced to LWOP from youth offender parole violated his right to equal protection under the federal and state constitutions and violated the California Constitution’s ban on cruel or unusual punishment. Two months later, defendant’s appointed counsel advised the trial court that defendant was ineligible for relief and made an oral motion to have the matter taken off calendar, which the court granted.3 In December 2024,4 defendant filed a handwritten motion for a Franklin hearing and appointment of counsel. Defendant argued section 3051’s exclusion of 18-to-25-year-old LWOP offenders from eligibility for youth offender parole hearings violates equal protection principles. Defendant contended there was no rational basis to make 18-to-25-year-old LWOP offenders ineligible for youth offender parole while 18-to-25-year-old offenders serving the functional equivalent of LWOP were so eligible. Although defendant stated in his motion’s preamble that his request was based on “equal protection an[d] cruel or unusual punishment principles,” he omitted any discussion of cruel or unusual punishment principles or their application to him from his supporting memorandum of points and authorities. That same day, the trial court summarily denied the motion. It found that because defendant was 19 years old at the time of Lee’s murder, “[h]e was not a juvenile offender and doesn’t qualify for [Franklin] assistance.”

3 This proceeding involved the same judge whose ruling is the subject of this appeal. 4 Although defendant mailed his motion to the trial court in mid- November 2024, it was not filed stamped by the superior court until December 5, 2024.

4 II. DISCUSSION Defendant makes two equal protection arguments—only one of which was made below. He argues, as he did in the trial court, that section 3051 violates equal protection principles by treating young adult offenders sentenced to LWOP differently than young adult offenders serving non-LWOP sentences for murder. As defendant concedes, this argument was rejected by our Supreme Court in People v. Hardin (2024) 15 Cal.5th 834 and that holding is binding. Defendant additionally contends section 3051 violates equal protection principles because juvenile offenders (under 18 years of age) sentenced to LWOP are entitled to parole hearings while young adult offenders (18 to 25 years old) are not. This argument is forfeited because it was not raised in the trial court and it is also unpersuasive because the distinction drawn by the Legislature has a rational basis. Defendant additionally contends the exclusion of young adult offenders sentenced to LWOP from youth parole hearings constitutes cruel or unusual punishment. This argument also was not made below and it is forfeited. Even putting aside the forfeiture, numerous appellate courts have upheld LWOP (and de facto LWOP) sentences for young adults against cruel or unusual punishment claims, and our Supreme Court has held that even death sentences are not unconstitutionally disproportionate for a homicide committed by an offender 18 years old or older.

A. Section 3051 Section 3051 requires the Board of Parole Hearings to conduct a “youth offender parole hearing” during the 15th, 20th, or 25th year of a defendant's incarceration if they were 25 years

5 or younger at the time of the “controlling offense,” i.e., “the offense or enhancement for which any sentencing court imposed the longest term of imprisonment.” (§ 3051, subds. (a)(1), (a)(2)(B), (b)(1)-(4).) The statute excludes several categories of offenders, however, including those who (like defendant) are “sentenced to life in prison without the possibility of parole for a controlling offense that was committed after the person had attained 18 years of age.” (§ 3051, subd.

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Bluebook (online)
People v. Thomas CA2/5, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-thomas-ca25-calctapp-2026.