Articles Posted in Uncategorized

People v. Campbell (Cal. Ct. App., Aug. 3, 2026, No. B334456) 2026 WL 2577310

Summary: In People v. Campbell, the California Court of Appeal reconsidered whether Sidney Campbell was entitled to resentencing relief under Penal Code section 1172.6 following significant developments in California law governing murder liability and resentencing petitions. The case arose after the California Supreme Court transferred the matter back to the Court of Appeal for reconsideration in light of People v. Lopez (2025) 19 Cal.5th 639. Although Lopez expanded the circumstances under which petitioners may seek relief, the Court of Appeal ultimately concluded that Campbell remained ineligible for resentencing as a matter of law because the jury instructions in his case required a finding that he personally acted with malice.

The Crime and Conviction

People v. Esquivias (Cal., Aug. 17, 2026, No. S286371) 2026 WL 2386584, at *1–10

Summary: A habeas corpus court has broad equitable authority to craft relief “as the justice of the case may require.” (In re Palmer (2021) 10 Cal.5th 959, 976; Pen. Code, § 1484.) Petitioner Miguel Alberto Esquivias sought habeas relief based solely on Senate Bill No. 620, which gave trial courts discretion to strike previously mandatory firearm enhancements. The superior court granted that targeted relief by striking those enhancements, but declined to reopen the entire sentence. The Court of Appeal affirmed, holding that habeas relief is not an “all-or-nothing” remedy. The California Supreme Court agreed thatbecause Esquivias’s original sentence was valid and neither the Constitution nor any statute required full resentencing, the habeas court could limit relief to the firearm enhancements.

Factual and Procedural History

People v. Valencia (Cal. Ct. App., Mar. 10, 2026, No. B338672) 2026 WL 672932, at *1

Summary: Valencia, under the influence of methamphetamine and cocaine, drove his pickup truck and would not comply with police orders to pull over. Police chased Valencia until he crashed into a parked car. Valencia jumped out, ran to his nearby apartment, and barricaded himself in his bedroom. During an overnight standoff, Valencia shot one officer to death and seriously wound another. A SWAT team eventually blew through his bedroom wall and blasted down his bedroom door. The jury convicted Valencia of murder and other felonies.

Valencia appealed challenging the warrantless entry of police into his apartment. The Court of Appeal held that jurors could find exigent circumstances justified the initial warrantless entry and that police did not need to seek a warrant once they were in the apartment.

People v. Flores (Cal. Ct. App., Feb. 11, 2026, No. A171602) 2026 WL 378414, at *1

Summary: Flores pleaded no contest to felony possession of fentanyl for sale and was sentenced to two years of formal probation with a condition permitting warrantless searches of Flores’s electronic devices. On appeal, Flores asked the court to strike or modify the electronics search clause as unconstitutionally overbroad and unreasonable. Because Flores used electronic devices to coordinate the sale and to obscure his identity during negotiations, the court affirmed  the electronics search clause in its entirety.

In its presentencing report, the probation department recommended “a five-way search clause to include all electronic devices, and supply passwords upon request due to [Flores] using his cell phone to negotiate the sale of illicit controlled substances.” The report  stated that at the time of the offense, Flores had been on formal probation in Merced for possession of a controlled substance for sale (Health & Saf. Code, § 11351), and that Flores admitted to using fentanyl and a prior gang affiliation.

People v. Kopp (Cal., Dec. 29, 2025, No. S257844) 2025 WL 3755596, at *1–5

Summary: Co-defendant Hernandez challenged various punitive fines, along with other ancillary costs, ordered as part of a criminal sentencing. The California Supreme Court held that a challenge to the amount of a criminal fine should initially be reviewed under the excessive fines provisions of the United States and California Constitutions.

The imposition of ancillary payments raises separate equal protection issues. A court must consider a defendant’s inability to pay before imposing a court operations assessment (Pen. Code, § 1465.8, subd. (a)(1)) or a court facilities assessment (Gov. Code, § 70373, subd. (a)(1)). The Court urged the Legislature to revisit issues surrounding court-ordered ancillary payments in criminal cases and address them in a more comprehensive manner.

People v. Demacedo (Cal. Ct. App., Nov. 12, 2025, No. A170580) 2025 WL 3169575, at *1–4

Summary: Demacedo was convicted of three counts of gross vehicular manslaughter while intoxicated (Pen. Code, § 191.5, subd. (a)) for the death of  three victims, as well as felony violations of Vehicle Code section 23153, subdivisions (a) and (b) for driving under the influence of alcohol and with an elevated blood alcohol level and causing injury to Sarah (DUI causing injury).

Demacedo argued that  the DUI causing injury counts must be dismissed as lesser included offenses of the vehicular manslaughter while intoxicated convictions. The Court of Appeal held that a violation of Vehicle Code section 23153 is not a lesser included offense of Penal Code section 191.5, subdivision (a) when the offenses involve different victims.