People v. Wilson
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In 2004, Wilson was charged with shooting three people, killing two. Wilson argued that a deceased third party was the actual perpetrator. A jury found Wilson guilty of two counts of first-degree murder and one count of willful, deliberate, and premeditated attempted murder but was unable to reach a verdict on allegations that he personally used and intentionally discharged a firearm in the commission of the offense, causing great bodily injury and death. The court of appeal affirmed, stating there was sufficient evidence to support the convictions on a theory of accomplice liability and even “sufficient evidence to support a conviction on the direct perpetrator theory.”
In 2018, Senate Bill 1437 amended the felony murder rule and the natural and probable consequences doctrine, 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 underlying felony who acted with reckless indifference to human life.
The court of appeal affirmed the denial of Wilson’s petition for resentencing. A jury’s inability to reach a verdict on the sentencing enhancement allegations for personally using and discharging a firearm does not preclude the court, in a subsequent Penal Code section 1170.95 hearing, from finding beyond a reasonable doubt that the defendant was the actual shooter. The evidence was sufficient for a trier of fact to conclude, beyond a reasonable doubt, that Wilson was guilty as the actual shooter.
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