People v. Watson CA2/1

California Court of Appeal Sep 19, 2024 No. B336720Unpublished

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Holding. The court affirmed the denial of the defendant's petition for resentencing under Penal Code section 1172.6, finding that the defendant's claims were outside the scope of the statute and that he was ineligible for relief because he pleaded no contest after the relevant statutory amendments took effect and was the actual killer.

Issues

Whether the defendant is entitled to resentencing under Penal Code section 1172.6 for a murder conviction entered after the effective date of the relevant statutory amendments.
Whether the defendant's claims regarding his plea agreement and ineffective assistance of counsel are cognizable in a section 1172.6 proceeding.

Disposition. Affirmed

Quotations verified verbatim against the opinion

“The issues raised by Watson are outside the scope of a section 1172.6 resentencing proceeding and fail to demonstrate any error in the court’s denial of his petition.”

“Senate Bill [No.] 1437 relief is unavailable if the defendant was . . . the actual killer”

“None of these arguments is cognizable in a section 1172.6 proceeding, the purpose of which “ ‘is to give defendants the benefit of amended sections 188 and 189’ ” and “ ‘not to provide a do-over’ ” on unrelated issues regarding their conviction.”

Filed 9/19/24 P. v. Watson CA2/1 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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 ONE

THE PEOPLE, B336720

Plaintiff and Respondent, (Los Angeles County Super. Ct. No. SA100813) v.

SAMUEL R. WATSON,

Defendant and Appellant.

APPEAL from an order of the Superior Court of Los Angeles County, Christopher W. Dybwad, Judge. Affirmed. Larry Pizarro, under appointment by the Court of Appeal, for Defendant and Appellant. No Appearance for Plaintiff and Respondent.

______________________

INTRODUCTION In 2020, defendant Samuel R. Watson was charged with murder and elder abuse causing death. In 2022, he pleaded no contest to second degree murder pursuant to a plea agreement. In 2023, Watson filed a petition for resentencing under Penal Code1 section 1172.6. The trial court denied the petition and Watson now appeals that decision. His appellate counsel filed a brief pursuant to People v. Delgadillo (2022) 14 Cal.5th 216, identifying no issues on appeal. Watson filed a supplemental brief raising certain contentions about his conviction, but none concerns the merits of his resentencing petition. The issues raised by Watson are outside the scope of a section 1172.6 resentencing proceeding and fail to demonstrate any error in the court’s denial of his petition. Accordingly, we affirm. POSTCONVICTION RELIEF UNDER SECTION 1172.6 We begin by briefly summarizing section 1172.6, which was enacted in 2018 as part of Senate Bill No. 1437 (2017-2018 Reg. Sess.).2 The legislation’s overall purpose was “to amend 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

People v. Watson CA2/1

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IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION ONE

THE PEOPLE, B336720

SAMUEL R. WATSON,

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