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Name: People v. Watson
Case #: D069324
Court: CA Court of Appeal
District 4 DCA
Division: 1
Opinion Date: 02/10/2017

Reimposition of LWOP sentence for defendant who committed a homicide as a juvenile was appropriate after trial court found this to be a rare case reflecting irreparable corruption. In 1994, when Watson was just four months shy of his eighteenth birthday, he shot and killed a woman who resisted his attempt to rob her. He was not identified as the killer for a number of years after the crime. A jury found him guilty of special circumstance murder during a robbery and he received an LWOP sentence. His conviction was affirmed on direct appeal. Sometime later, Watson was granted a new sentencing hearing under Penal Code section 190.5, subdivision (b) and Miller v. Alabama (2012) 132 S.Ct. 2455. The trial court reimposed the LWOP term, finding this to be one of the rare cases reflecting irreparable corruption. Watson appealed. Held: Affirmed. In Miller, the Court determined the Eighth Amendment prohibits the imposition of a mandatory LWOP sentence on a juvenile homicide offender. In homicide cases involving juveniles, the trial court is required to consider how children are different and how a juvenile’s distinctive (and transitory) mental traits and environmental vulnerability might constitute mitigating factors at sentencing. However, Miller did not foreclose the imposition of an LWOP sentence on the rare juvenile homicide offender whose crime reflects irreparable corruption. In this case the trial court carefully considered the Miller factors and reimposed an LWOP sentence. The term imposed does not violate the Eighth Amendment.

The trial court did not abuse its discretion by reimposing an LWOP sentence. Watson claimed the trial court abused its discretion by failing to sufficiently consider the requisite factors under Miller v. Alabama and People v. Gutierrez (2014) 58 Cal.4th 1354 (discussing youth related factors court is required to consider in sentencing juvenile offender) when it imposed an LWOP sentence. However, this claim is undermined by the record, which reflects the trial court thoughtfully considered the applicable factors, including Watson’s youth, the facts of the offense, and Watson’s criminal offenses since he committed the homicide, before determining that he “was unfit ever to reenter society.”

The full opinion is available on the court’s website here: