People v. Villalpando CA5

CourtCalifornia Court of Appeal
DecidedMarch 10, 2025
DocketF086978
StatusUnpublished

This text of People v. Villalpando CA5 (People v. Villalpando CA5) 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. Villalpando CA5, (Cal. Ct. App. 2025).

Opinion

Filed 3/10/25 P. v. Villalpando CA5

NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

FIFTH APPELLATE DISTRICT

THE PEOPLE, F086978 Plaintiff and Respondent, (Super. Ct. No. BF180864A) v.

JONATHAN VILLALPANDO, OPINION Defendant and Appellant.

APPEAL from a judgment of the Superior Court of Kern County. Brian M. McNamara, Judge. Ross Thomas, under appointment by the Court of Appeal, for Plaintiff and Appellant. Rob Bonta, Attorney General, Lance E. Winters, Chief Assistant Attorney General, Kimberley A. Donohue, Assistant Attorney General, Eric L. Christoffersen and Chung Mi Choi, Deputy Attorneys General, for Plaintiff and Respondent. -ooOoo- Defendant Jonathan Villalpando appeals following his 2023 conviction and sentencing for voluntary manslaughter with a firearm enhancement. (Pen. Code, §§ 192, subd. (a), 12022.5, subd. (a).)1 The sole claim raised on appeal is sentencing error under section 1170, subdivision (b), as amended by Senate Bill No. 567.2 The trial court imposed upper terms for manslaughter and for the firearm enhancement. Defendant claims the court relied on aggravating factors that were not found in compliance with the amended statute, entitling him to vacatur of his sentence and remand for resentencing. The People take the position that defendant forfeited his claim by failing to object and, alternatively, that any errors were harmless. In view of the California Supreme Court’s recent and substantial clarification of the law in Lynch, we decline to apply the forfeiture doctrine to defendant’s claim of sentencing error. (People v. Lynch (2024) 16 Cal.5th 730 (Lynch).)3 In accordance with Lynch, supra, at page 768, we conclude the trial court violated defendant’s Sixth Amendment rights when it found, based on defendant’s past juvenile adjudications, that “defendant has engaged in violent conduct that indicates a serious danger to society.” (Cal. Rules of Court, rule 4.421(b)(1).)4 The error is prejudicial under Chapman v. California (1967) 386 U.S. 18 (Chapman) and, therefore, we vacate defendant’s sentence and remand this matter for a full resentencing. (Lynch, supra, at p. 775.)

1 All further statutory references are to the Penal Code. 2 Senate Bill No. 567 (2021–2022 Reg. Sess.) (Senate Bill 567) (eff. Jan. 1, 2022). 3 The decision in Lynch was issued after defendant filed his opening brief but before the People filed their respondent’s brief. Defendant did not file a reply brief. 4 All further references to rules are to the California Rules of Court.

2. PROCEDURAL BACKGROUND In May 2020, during an altercation in his mother’s backyard, defendant shot and killed Eric Futrell, whom he had known since childhood.5 Defendant was arrested and charged with willful, deliberate and premeditated murder with a firearm enhancement under section 12022.53, subdivision (d). Jury trial commenced in April 2023. In May 2023, the jury returned a verdict acquitting defendant of first and second degree murder, but convicting him of voluntary manslaughter and finding that he personally used a firearm in the commission of the felony under section 12022.5, subdivision (a). In addition, the jury found true the allegations that “[t]he crime involved great violence, great bodily harm, threat of great bodily harm, or other acts disclosing a high degree of cruelty, viciousness, or callousness,” and that “defendant was armed with or used a weapon at the time of the commission of the crime” (rule 4.421(a)(1), (2)). The jury found not true the allegation that “[t]he manner in which the crime was carried out indicates planning, sophistication, or professionalism” (rule 4.421(a)(8)). Defendant was sentenced in October 2023. Based on the two aggravating factors found true by the jury and three additional factors set forth in the probation report, the trial court found the five aggravating factors outweighed the two mitigating factors it found, as discussed below. The court then sentenced defendant to the upper term of 11 years for manslaughter and the upper term of 10 years for the firearm enhancement, for a total determinate term of 21 years. Defendant filed a timely notice of appeal.

5 We need not include a detailed summary of the trial evidence because it is unnecessary to the resolution of defendant’s claim of sentencing error under section 1170.

3. DISCUSSION I. Background A. Senate Bill 567 Effective January 1, 2022, Senate Bill 567 amended section 1170, codifying the holding in Cunningham “that, ‘under the Sixth Amendment, any fact that exposes a defendant to a greater potential sentence must be found by a jury, not a judge, and established beyond a reasonable doubt, not merely by a preponderance of the evidence.’” (Lynch, supra, 16 Cal.5th at p. 742, quoting Cunningham v. California (2007) 549 U.S. 270, 281.) “‘Inhering in that guarantee is an assurance that a guilty verdict will issue only from a unanimous jury.’” (Lynch, supra, at p. 742, citing Erlinger v. United States (2024) 602 U.S. 821, 830 (Erlinger) & Ramos v. Louisiana (2020) 590 U.S. 83, 90, 92– 93.) As amended, section 1170, subdivision (b), now provides: “(b) [¶] (1) When a judgment of imprisonment is to be imposed and the statute specifies three possible terms, the court shall, in its sound discretion, order imposition of a sentence not to exceed the middle term, except as otherwise provided in paragraph (2). “(2) The court may impose a sentence exceeding the middle term only when there are circumstances in aggravation of the crime that justify the imposition of a term of imprisonment exceeding the middle term and the facts underlying those circumstances have been stipulated to by the defendant or have been found true beyond a reasonable doubt at trial by the jury or by the judge in a court trial. Except where evidence supporting an aggravating circumstance is admissible to prove or defend against the charged offense or enhancement at trial, or it is otherwise authorized by law, upon request of a defendant, trial on the circumstances in aggravation alleged in the indictment or information shall be bifurcated from the trial of charges and enhancements. The jury shall not be informed of the bifurcated allegations until there has been a conviction of a felony offense.

4. “(3) Notwithstanding paragraphs (1) and (2), the court may consider the defendant’s prior convictions in determining sentencing based on a certified record of conviction without submitting the prior convictions to a jury. This paragraph does not apply to enhancements imposed on prior convictions. “(4) At least four days prior to the time set for imposition of judgment, either party or the victim, or the family of the victim if the victim is deceased, may submit a statement in aggravation or mitigation to dispute facts in the record or the probation officer’s report or to present additional facts. The court may consider the record in the case, the probation officer’s report, other reports, including reports received pursuant to Section 1203.03, and statements in aggravation or mitigation submitted by the prosecution, the defendant, or the victim, or the family of the victim if the victim is deceased, and any further evidence introduced at the sentencing hearing.

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Related

Chapman v. California
386 U.S. 18 (Supreme Court, 1967)
Almendarez-Torres v. United States
523 U.S. 224 (Supreme Court, 1998)
Blakely v. Washington
542 U.S. 296 (Supreme Court, 2004)
Cunningham v. California
549 U.S. 270 (Supreme Court, 2007)
People v. McCullough
298 P.3d 860 (California Supreme Court, 2013)
People v. Watson
299 P.2d 243 (California Supreme Court, 1956)
People v. Reyes
195 Cal. App. 3d 957 (California Court of Appeal, 1987)
People v. Martinez
84 Cal. Rptr. 2d 638 (California Court of Appeal, 1999)
People v. French
178 P.3d 1100 (California Supreme Court, 2008)
People v. Black
161 P.3d 1130 (California Supreme Court, 2007)
People v. Sandoval
161 P.3d 1146 (California Supreme Court, 2007)
In Re Sheena K.
153 P.3d 282 (California Supreme Court, 2007)
People v. Gutierrez
324 P.3d 245 (California Supreme Court, 2014)
People v. Sivongxxay
396 P.3d 424 (California Supreme Court, 2017)
Ramos v. Louisiana
590 U.S. 83 (Supreme Court, 2020)
People v. Dueñas
242 Cal. Rptr. 3d 268 (California Court of Appeals, 5th District, 2019)
Erlinger v. United States
602 U.S. 821 (Supreme Court, 2024)

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People v. Villalpando CA5, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-villalpando-ca5-calctapp-2025.