People v. Monroe CA2/8

Filed 8/25/25 P. v. Monroe CA2/8 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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 EIGHT

THE PEOPLE, B334375

Plaintiff and Respondent, (Los Angeles County Super. Ct. No. MA073532) v.

JAMIE MONROE,

Defendant and Appellant.

APPEAL from an order of the Superior Court of Los Angeles County. Robert G. Chu, Judge. Affirmed. Joanna McKim, under appointment by the Court of Appeal, for Defendant and Appellant. Rob Bonta, Attorney General, Lance E. Winters, Chief Assistant Attorney General, Susan Sullivan Pithey, Assistant Attorney General, Noah P. Hill and Kathy S. Pomerantz, Deputy Attorneys General, for Plaintiff and Respondent. _______________________________________

INTRODUCTION In January 2019, Senate Bill No. 1437 (2017–2018 Reg. Sess.) amended murder law to ensure liability is not imposed on a defendant who was not the actual killer, did not act with the intent to kill, or was not a major participant in the underlying felony who acted with reckless indifference to human life. The legislation also added what is now Penal Code1 section 1172.6, which created a mechanism for defendants previously convicted of a qualifying homicide offense under the former law to petition for retroactive relief. In April 2021, the People filed the operative information, charging defendant Jamie Monroe with two counts of murder. In January 2023, a jury convicted Monroe of one count of first degree murder, and it found true a robbery-murder special circumstance allegation. While her direct appeal was pending, Monroe petitioned for resentencing under section 1172.6, challenging her murder conviction. The court denied Monroe’s petition without appointing counsel to represent her, finding she failed to make a prima facie showing of eligibility for relief. On appeal, Monroe contends the court erred by summarily denying her petition without appointing counsel to represent her or affording her a hearing and the opportunity to file additional briefing. Because the People charged and tried Monroe well after Senate Bill No. 1437 went into effect, she is ineligible for relief under section 1172.6 as a matter of law. Any error in failing to appoint counsel to represent Monroe or in denying her the