People v. Wilson CA1/1

CourtCalifornia Court of Appeal
DecidedMarch 3, 2025
DocketA166666
StatusUnpublished

This text of People v. Wilson CA1/1 (People v. Wilson CA1/1) 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. Wilson CA1/1, (Cal. Ct. App. 2025).

Opinion

Filed 3/3/25 P. v. Wilson CA1/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION ONE

THE PEOPLE, Plaintiff and Respondent, A166666 v. DENISE MAE WILSON, (Contra Costa County Super. Ct. No. 04001999432) Defendant and Appellant.

A jury convicted Denise Mae Wilson of arson. The trial court placed Wilson on formal probation for two years. Wilson maintains there was insufficient evidence to support her arson conviction. She further contends the court erred in instructing the jury on aiding and abetting without evidence to support those instructions. Lastly, she agrees with the People that a remand for resentencing is warranted. We agree a remand is appropriate to permit the trial court to clarify its sentence. In all other respects, we affirm the judgment. I. BACKGROUND A. The Arson In April 2020, Wilson’s boyfriend, Idrees Hollis, was staying with his ex-girlfriend, Tanisha Gilmore, after he and Wilson had a falling out. Around 1:40 a.m. on April 15, 2020, Gilmore heard banging at her front door and someone yelling for Hollis to open the door. She recognized the voice as Wilson’s voice. She looked out her window and saw Wilson with another woman, whom she did not recognize. Afraid that the two women would break her windows, Gilmore called the police. She then heard someone say, “ ‘Oh, so you’re not going to open the door,’ ” and it was “quiet for a minute.” After a while, Gilmore saw lights outside, and she thought it was the police. She instead found her van on fire. She did not see Wilson outside at that point. Gilmore’s neighbor was woken up by the banging on Gilmore’s door. She saw two women “peeking” in a van parked in front of Gilmore’s house. The neighbor heard the women shout, “ ‘Come out the house, B. We know you in there so you might as well come out. You must be scared because you ain’t came out by now, so come on out.’ ” The neighbor could not see the women’s faces because it was dark. Eventually, the two women left, but the neighbor heard them return a little later. She saw them peer into Gilmore’s windows before walking to Gilmore’s van. They opened the van’s front passenger door, “took some clothes out or something,” and “roam[ed] through [the van].” And “all of a sudden,” the neighbor saw “some flickering, and then . . . like a flash of light,” and flames “quickly went up.” The women then “rac[ed] down the street” and left in a car. Later that day or the following day, Wilson left a voicemail for Gilmore saying, “You aint finna do a mother fucking thing bitch but get knocked out. Bitch you wanted these problems, bitch. You already knew . . . it was going to be a problem with me bitch when you came and picked up my nigga.”

2 A fire investigator testified that an ignitable liquid or accelerant was likely used to start the fire, and it was poured over the top of the front passenger seat. Approximately 15 minutes before Gilmore’s first call to the police, a car registered to Wilson was scanned by automated license plate reading cameras en route to Gilmore’s house. Wilson denied driving to Gilmore’s house and setting fire to her van, and she claimed her and Hollis broke up in the month prior to the incident. B. Relevant Procedural History Wilson was charged with one felony count of arson. (Pen. Code, § 451, subd. (d).) It was also alleged that three aggravating circumstances applied to the arson charge. The trial court’s jury instructions included an instruction on aiding and abetting pursuant to CALCRIM No. 401. The jury returned a guilty verdict and found true two of the aggravating circumstances. The court suspended execution of sentence and placed Wilson on formal probation. II. DISCUSSION A. Sufficiency of the Evidence Wilson argues the record contains insufficient evidence to convict her of arson as either the direct perpetrator or as an aider and abettor. As we will explain, we need not determine whether there is sufficient evidence to support Wilson’s arson conviction on a direct perpetrator theory because the evidence was sufficient to establish beyond a reasonable doubt that Wilson’s conduct assisted in the commission of the arson.1

1 To the extent the evidence is insufficient to support a direct

perpetrator theory, we affirm unless a review of the entire record affirmatively demonstrates a reasonable probability that the jury in fact

3 1. Legal Principles and Standard of Review In reviewing claims of insufficient evidence, we “ ‘ “ ‘must review the whole record in the light most favorable to the judgment below to determine whether it discloses substantial evidence—that is, evidence which is reasonable, credible, and of solid value—such that a reasonable trier of fact could find the defendant guilty beyond a reasonable doubt.’ ” ’ ” (People v. Halvorsen (2007) 42 Cal.4th 379, 419, called into doubt on another ground by People v. Johnson (2012) 53 Cal.4th 519, 527–528.) “We presume ‘ “in support of the judgment the existence of every fact the trier could reasonably deduce from the evidence.” [Citation.] This standard applies whether direct or circumstantial evidence is involved.’ ” (People v. Prince (2007) 40 Cal.4th 1179, 1251.) “Under California law, a person who aids and abets the commission of a crime is a ‘principal’ in the crime, and thus shares the guilt of the actual perpetrator.” (People v. Prettyman (1996) 14 Cal.4th 248, 259, superseded by statute on other grounds as stated in People v. Lopez (2023) 88 Cal.App.5th 566, 575.) “[P]roof of aider and abettor liability requires proof in three distinct areas: (a) the direct perpetrator’s actus reus—a crime committed by the direct perpetrator, (b) the aider and abettor’s mens rea—knowledge of the direct perpetrator’s unlawful intent and an intent to assist in achieving those unlawful ends, and (c) the aider and abettor’s actus reus—conduct by the aider and abettor that in fact assists the achievement of the crime.” (People

relied on the unsupported theory. (People v. Perez (2005) 35 Cal.4th 1219, 1233.) Wilson does not argue that the verdict actually rested on a direct perpetrator theory. We therefore presume the record does not affirmatively demonstrate that the jury relied on a direct perpetrator theory in convicting Wilson of arson. (See Dilbert v. Newsom (2024) 101 Cal.App.5th 317, 323 [burden on appellant to affirmatively demonstrate error].)

4 v. Perez, supra, 35 Cal.4th at p. 1225.) The test is “whether the accused in any way, directly or indirectly, aided the perpetrator by acts or encouraged him by words or gestures.” (People v. Villa (1957) 156 Cal.App.2d 128, 134.) 2. Analysis Wilson acknowledges there was evidence showing she was present at the scene of the crime with another woman when the fire started. Nor does she dispute that the jury could have reasonably inferred from the evidence that one of the two women set Gilmore’s van on fire, even though no one was able to say who actually started the fire. Wilson contends, however, that there was no evidence of the aider and abettor’s actus reus because “there was no testimony that one [woman] handed the other any item, or said any encouraging words, or provided any service other than her presence.” While it is true that “ ‘[m]ere presence at the scene of a crime’ ” and the failure to prevent a crime alone are insufficient to constitute aiding and abetting, “ ‘these are factors the jury may consider in assessing a defendant’s criminal responsibility.’ ” (People v.

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People v. Wilson CA1/1, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-wilson-ca11-calctapp-2025.