People v. Williams CA4/1

CourtCalifornia Court of Appeal
DecidedMay 14, 2024
DocketD080892
StatusUnpublished

This text of People v. Williams CA4/1 (People v. Williams CA4/1) 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. Williams CA4/1, (Cal. Ct. App. 2024).

Opinion

Filed 5/14/24 P. v. Williams CA4/1

NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

COURT OF APPEAL, FOURTH APPELLATE DISTRICT

DIVISION ONE

STATE OF CALIFORNIA

THE PEOPLE, D080892

Plaintiff and Respondent,

v. (Super. Ct. No. SCD207315)

OCTAVUS VANSHON WILLIAMS,

Defendant and Appellant.

APPEAL from a judgment of the Superior Court of San Diego County, Robert F. O’Neill, Judge. Affirmed. Request for judicial notice denied. Lizabeth Weis, under the 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, Christopher P. Beesley and Michael D. Butera, Deputy Attorneys General, for Plaintiff and Respondent. In this appeal, we affirm the denial of the petitioner’s second

resentencing request under Penal Code section 1172.6.1 Contrary to his claim, changes made to the resentencing law by Senate Bill No. 775 (Senate Bill 775) after the denial of his first petition have no bearing on his conviction. And although the trial court should have appointed counsel before denying the petition at the prima facie stage, this or any other procedural error made by the trial court was harmless because petitioner is ineligible for relief as a matter of law.

FACTUAL AND PROCEDURAL BACKGROUND

In 2008, Octavus Vanshon Williams was convicted by a jury for the murder of Gregory Harper. In 2010, this court affirmed his conviction in an unpublished opinion. (People v. Williams (Sept. 21, 2010, D054769)

(Williams I).)2 We offer only a brief summary of the facts, which are undisputed in this appeal, for context. Williams was a high ranking member of the Skyline gang. Offended by what he perceived as slights to his status by Harper, a more junior gang member, he and another senior gang member, Andre Brown, confronted Harper in the apartment of a fourth gang member and beat him up. Williams, Brown and Harper then left the apartment. Two days later,

1 All further undesignated statutory references are to the Penal Code. Section 1172.6 was previously numbered 1170.95. For simplicity, we refer to it as section 1172.6 throughout. 2 This is the first of two unpublished opinions related to this case that we reference under an exception to the general rule that unpublished opinions are not citable. (Cal. Rules of Court, rule 8.1115(b)(2) [unpublished opinions may be cited when, as here, “the opinion is relevant to a criminal or disciplinary action because it states reasons for a decision affecting the same defendant or respondent in another such action.”].) 2 Harper’s body was discovered in the back of the car he had driven to meet Williams and Brown. He died of strangulation. (Williams I, supra, D054769.) A jury acquitted Williams of first degree murder, necessarily rejecting theories of premeditation and felony murder. Instead, he was convicted of second degree murder with implied malice. (§ 187, subd. (a); Williams I, supra, D054769.) Brown subsequently pleaded guilty to the same offense. In 2019, Williams filed a petition for resentencing under section 1172.6. In that matter, “[t]he trial court appointed counsel, received briefing, reviewed the record of conviction, and heard argument. The court denied the petition, finding Williams was prosecuted as a direct aider and abettor and that the jury was not instructed on felony murder for second degree murder and the jury was not instructed on the natural and probable consequences doctrine for that offense.” (People v. Williams (Oct. 12, 2021, D078714) (Williams II).) We affirmed this denial. Williams subsequently filed a second petition in which he argued that changes made to section 1172.6 by Senate Bill 775 entitled him to resentencing relief. The trial court denied his request summarily, recalling the basis for its previous denial and reasoning that Williams was collaterally estopped from bringing a second petition because “no change in the applicable law or facts . . . justify the filing of a successive petition.” That second denial is the subject of this appeal.

DISCUSSION

Senate Bill No. 1437 “ ‘amend[ed] the felony murder rule and the natural and probable consequences doctrine, as it relates to murder, to ensure that murder liability is not imposed on a person who is not the actual killer, did not act with the intent to kill, or was not a major participant in the

3 underlying felony who acted with reckless indifference to human life.’ ” (People v. Lewis (2021) 11 Cal.5th 952, 959 (Lewis).) To accomplish this, it revised sections 188 and 189 and added section 1172.6 to create a procedure by which defendants previously convicted of murder under a now- unavailable theory of liability can seek resentencing. (Lewis, at p. 959.) With Senate Bill 775, the Legislature expanded this form of relief to include murder convictions stemming from “any theory under which malice is imputed to a person based solely on that person’s participation in a crime,” as well as attempted murder and manslaughter convictions that were similarly based on the prosecution’s ability to proceed under a felony murder or natural and probable consequences doctrine. (Stats. 2021, ch. 551 (2021– 2022 Reg. Sess.); § 188, subd. (a)(3).) Williams claims the trial court erred in dismissing his second section 1172.6 petition primarily by (1) failing to appoint counsel at the prima facie stage, (2) relying on records it was prohibited from considering, namely our prior opinion, and (3) raising on its own and ultimately invoking the collateral estoppel effect of the order denying the first petition. He further argues these errors were prejudicial because his record of conviction does not conclusively establish he is ineligible for relief as a matter of law. As we explain below, Williams should have been afforded the benefit of counsel before the court decided whether his petition stated a prima facie case for relief. But irrespective of that error or any others, there is no prejudice to Williams. As we concluded in the first appeal, the trial court properly denied his first petition. And Senate Bill 775, which was enacted thereafter, made no changes that potentially affected his conviction. As a result, Williams remains ineligible for resentencing as a matter of law.

4 We agree with Williams’s first contention. Consistent with the reasoning of Lewis, supra, 11 Cal.5th 952, he was entitled to the appointment of counsel “upon the filing of a compliant petition” and before the trial court

decided whether he had made a prima facie showing.3 (Lewis, at p. 963.) The fact that the court chose to raise a legal issue not addressed in Williams’s second petition—the collateral estoppel effect of the order denying his first petition—as a basis for rejecting it was yet another reason why counsel should have been appointed. Even so, any error in failing to appoint counsel does not require reversal unless Williams can show it is reasonably probable that with the assistance of counsel, his second petition would not have been summarily denied without an evidentiary hearing. (Id. at p. 974.) A similar prejudice analysis applies to Williams’s claim that the trial court should not have raised the collateral estoppel issue on its own motion and that doing so violated his due process rights as well as separation of powers principles. It does not matter if Williams is correct on all or only some of his contentions, because as a matter of law, he remains ineligible for

Free access — add to your briefcase to read the full text and ask questions with AI

Related

People v. Gentile
477 P.3d 539 (California Supreme Court, 2020)
People v. Lewis
491 P.3d 309 (California Supreme Court, 2021)

Cite This Page — Counsel Stack

Bluebook (online)
People v. Williams CA4/1, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-williams-ca41-calctapp-2024.