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People v. Reyes, 14 Cal.5th 981, 531 P.3d 357, 309 Cal.Rptr.3d 832, 2023 Daily Journal D.A.R. 6432

Facts

Defendant Andres Quinonez Reyes was convicted of second-degree murder following a gang-related shooting where he was not the actual shooter. Reyes participated in a bicycle ride to rival gang territory with other gang members, one of whom shot the victim. After the Legislature eliminated the 'natural and probable consequences' theory of liability, Reyes petitioned for resentencing, arguing that the evidence did not support a murder conviction under any valid theory. The trial court denied his petition, asserting that Reyes was guilty of implied malice murder.

Defendant Andres Quinonez Reyes was convicted of second degree murder following a homicide committed by a fellow member of Santa Ana's F-Troop gang. Reyes was one of several members or affiliates of F-Troop who were present when the killing occurred, although the evidence showed he was not the shooter.

Issue

Did the trial court err in denying Reyes's petition for resentencing based on the evidence and legal standards applicable to implied malice murder?

Did the trial court err in denying Reyes's petition for resentencing based on the evidence and legal standards applicable to implied malice murder?

Rule

To sustain a conviction for implied malice murder, the defendant's act must proximately cause the victim's death and involve a high degree of probability that it will result in death. The aider and abettor's mental state regarding the direct perpetrator's life-endangering act must also be considered.

Murder is committed with implied malice when the killing is proximately caused by an act, the natural consequences of which are dangerous to life, which act was deliberately performed by a person who knows that his conduct endangers the life of another and who acts with conscious disregard for life.

Analysis

The Supreme Court found that the evidence was insufficient to support a finding that Reyes committed an act that proximately caused the victim's death. The court noted that merely participating in a dangerous situation does not satisfy the causation requirement for implied malice murder. Additionally, the trial court erred by not properly considering Reyes's mental state concerning the direct perpetrator's actions, which is essential for establishing liability under the aiding and abetting theory.

On this record, it cannot be said that Reyes committed an act that 'proximately caused' Rosario's death. The prosecutor proceeded on the theory that Lopez shot Rosario, and no evidence was presented that Reyes's conduct was a 'substantial factor' that contributed to the shooting.

Conclusion

The Supreme Court reversed the trial court's denial of Reyes's resentencing petition and remanded the case for further proceedings, indicating that the trial court's conclusions were not supported by substantial evidence.

We find no substantial evidence to support the trial court's denial of Reyes's resentencing petition based on his liability for second degree murder on a direct perpetrator theory.

Who won?

The prevailing party in this case is Andres Quinonez Reyes, as the Supreme Court reversed the trial court's decision denying his petition for resentencing. The court found that the trial court had erred in its application of the law regarding implied malice murder and the requirements for aiding and abetting. This ruling allows Reyes the opportunity for a new hearing on his resentencing petition under the correct legal standards.

The prevailing party in this case is Andres Quinonez Reyes, as the Supreme Court reversed the trial court's decision denying his petition for resentencing.

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