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appealhearingwillparolerehabilitation
appealhearingtrialverdictpleawillleaseparolelife imprisonment

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In re Lawrence, 44 Cal.4th 1181, 190 P.3d 535, 82 Cal.Rptr.3d 169, 08 Cal. Daily Op. Serv. 11,070, 2008 Daily Journal D.A.R. 13,171

Facts

Sandra Davis Lawrence was convicted of first-degree murder for killing Rubye Williams in 1971. After serving nearly 24 years in prison, the Board of Parole Hearings found her suitable for parole multiple times, citing her rehabilitation and lack of disciplinary issues. However, the Governor repeatedly reversed these decisions, citing the gravity of the commitment offense. In 2005, the Board again recommended parole, leading to a legal challenge against the Governor's decision.

In 1971, Sandra Davis Lawrence (petitioner) murdered her lover's wife, Rubye Williams. Petitioner fled the state, remaining a fugitive until 1982, when she voluntarily returned to California and surrendered to the authorities. Petitioner declined a plea offer that would have resulted in a two-year prison sentence. After the jury returned a guilty verdict on a charge of first degree murder, the trial court imposed a sentence of life imprisonment—the statutory penalty for murders committed prior to November 8, 1978—and set a minimum eligible parole date of November 29, 1990.

Issue

Whether the Governor's reversal of the Board of Parole Hearings' decision to grant parole was supported by 'some evidence' that Lawrence posed a current threat to public safety.

Whether the Governor's reversal of the Board of Parole Hearings' decision to grant parole was supported by 'some evidence' that Lawrence posed a current threat to public safety.

Rule

The court established that the relevant inquiry in reviewing a parole decision is whether some evidence supports the conclusion that the inmate is unsuitable for parole due to current dangerousness, rather than merely confirming the seriousness of the commitment offense.

when a court reviews a parole decision of the Board of Parole Hearings or the Governor, the relevant inquiry is whether some evidence supports the decision of the Board or the Governor regarding whether the inmate constitutes a current threat to public safety, and not merely whether some evidence confirms certain factual findings regarding dangerousness.

Analysis

The Supreme Court analyzed the evidence presented and concluded that the Governor's reliance on the gravity of the commitment offense was insufficient to demonstrate that Lawrence currently posed a danger to public safety. The Court emphasized that the Board had found overwhelming evidence of her rehabilitation and suitability for parole, which outweighed the historical nature of the crime.

Applying the 'some evidence' standard to the case presently before us, we agree with the Court of Appeal that the record fails to support the Governor's conclusion that petitioner remains a current danger to public safety.

Conclusion

The Supreme Court affirmed the Court of Appeal's judgment, reinstating the Board's decision to grant Lawrence parole, concluding that the Governor's decision lacked the necessary evidentiary support.

Accordingly, we affirm the judgment of the Court of Appeal rendered in favor of petitioner.

Who won?

Sandra Davis Lawrence prevailed in the case because the Supreme Court found that the Governor's decision to deny her parole was not supported by sufficient evidence of current dangerousness.

Finding the Governor lacked 'some evidence' upon which to conclude, consistently with state and federal constitutional standards, that petitioner's release on parole would represent an 'unreasonable risk' of danger to the community, the Court of Appeal in a split decision issued a writ vacating the Governor's reversal and reinstating the Board's 2005 grant of a parole release to petitioner.

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