In People v. Esquivias, a 5-2 Supreme Court today holds a habeas corpus court granting some sentencing relief — based on a statute that applied retroactively to a judgment not yet final — is not required to reopen the entire sentence and consider applying other ameliorative statutes to grant additional relief.
The court’s opinion is by Justice Groban. Justice Evans writes a dissent in which Justice Liu joins.
The majority agrees “the procedural posture [of the case] is ‘rare and idiosyncratic’ ” and says the case has “unusual circumstances.” The petitioner got the superior court to strike firearm enhancements under 2017’s SB 620, but he was unsuccessful in thereafter having the Court of Appeal direct the superior court to determine the applicability of other statutes that could provide sentencing relief.
The Supreme Court finds the enhancements strike “neither constitutionally nor statutorily required [the habeas court] to vacate petitioner’s sentence in its entirety” and it states, “the habeas corpus court had broad equitable authority to conclude that ‘the justice of the case’ only required striking petitioner’s firearm enhancements. ([Pen. Code] § 1484.) Habeas corpus petitions must be assessed on a case-by-case basis, and this is not a case where petitioner’s original sentence was constitutionally infirm or unauthorized.” (Link added.)
The dissent asserts “the grant of habeas corpus relief reopens the finality of the sentence” such that, once the superior court struck the firearm enhancements, the petitioner’s entire sentence was not final and the lack of finality required the retroactive application of another, sentence-reducing statute. Justice Evans also “encourage[s] the Legislature to clarify whether it wishes courts to conduct full resentencing, applying current law, after a grant of habeas, or indeed in resentencing generally.”
The court affirms the published opinion by the Second District, Division Two, Court of Appeal. It disapproves the Second District, Division Eight, 2-1 decision in People v. Duenas (2025) 111 Cal.App.5th 553, to the extent Division Eight, as the Supreme Court puts it, stated a “broad proposition that a habeas corpus petitioner is always entitled to full resentencing whenever a habeas corpus court grants relief as to a portion of a petitioner’s sentence.” Duenas is a grant-and-hold for today’s decision (here).
Related:
