Skip to content
Name: People v. Hardin (2024) 15 Cal.5th 834
Case #: S277487
Court: CA Supreme Court
Opinion Date: 03/04/2024

Penal Code section 3051, which permits youth offender parole hearings, does not violate equal protection on its face, or as applied in this case, by its exclusion from eligibility of young adult offenders sentenced to LWOP. In 1989, at age 25, Hardin robbed and killed an elderly neighbor. He was convicted of a special circumstance murder and was sentenced to LWOP. Decades later, he filed a motion to develop evidence for a youth offender parole hearing. Hardin acknowledged that as an adult offender sentenced to LWOP, he was not eligible under section 3051, but argued his exclusion violated the federal…

View Full Summary
Name: People v. Ngo (2023) 89 Cal.App.5th 116
Case #: E078723
Court: CA Court of Appeal
District 4 DCA
Division: 2
Opinion Date: 03/10/2023

Penal Code section 3051 does not violate equal protection because there is a rational basis for excluding youthful offenders sentenced to LWOP from youthful offender parole hearings. Ngo, at the age of 19, was convicted of first degree murder, with a financial gain special circumstance and a firearm enhancement. He was sentenced to LWOP, plus 25 years-to-life. Ngo subsequently filed a motion for a Franklin hearing, requesting to preserve evidence of youth-related mitigating factors for purposes of a future youthful offender parole hearing pursuant to section 3051, which was denied due to his ineligibility as a result of his LWOP…

View Full Summary
Name: People v. Edwards
Case #: A147103
Court: CA Court of Appeal
District 1 DCA
Division: 4
Opinion Date: 04/10/2019

Penal Code section 3051, which mandates youthful-offender parole hearings for most defendants whose crimes were committed before age 25 and who receive de facto life sentences, violates equal protection by excluding youthful offenders sentenced under the One Strike law. In 2012, Edwards and Chioma, both 19 years old, were convicted on multiple counts of sexual assault and robbery committed against two victims. One Strike allegations were found true. Edwards was sentenced to 95 years to life; Chioma to 129 years to life. They challenged on equal protection grounds their exclusion from the provisions of section 3051, which mandates youthful-offender parole…

View Full Summary
Name: In re Cook
Case #: S240153
Court: CA Supreme Court
District CalSup
Opinion Date: 06/03/2019

A defendant entitled to a hearing under Penal Code sections 3051 and 4801 may seek the remedy of a Franklin proceeding, even if the offender's sentence is otherwise final. In 2007, Cook was sentenced to LWOP and five consecutive terms of 25 years to life for crimes committed when he was 17 years old. In 2014, Cook filed a habeas petition challenging his sentence as cruel and unusual punishment under the Eighth Amendment and Miller v. Alabama (2012) 567 U.S. 460. During Cook's habeas proceedings in the Court of Appeal, the court held (1) Cook's sentence was constitutional because…

View Full Summary
Name: In re Williams
Case #: B286241
District 2 DCA
Division: 2
Opinion Date: 06/20/2018

A youth offender granted parole under Penal Code section 3051 is not required to serve a consecutive sentence for an in-prison offense committed after age 25. In 1991, at age 21, Williams was convicted of first degree murder and was sentenced to 28 years to life. At age 26, he committed an in-prison battery, for which he was sentenced to an additional 8-year consecutive sentence. Williams was found suitable for parole in 2016, but the state held him to serve additional time for the in-prison offense. He filed a petition for writ of habeas corpus, arguing…

View Full Summary
Name: In re Jenson
Case #: B286056
Court: CA Court of Appeal
District 2 DCA
Division: 3
Opinion Date: 06/06/2018

Penal Code section 3051, which is the later-enacted and more specific statute regarding parole for youthful offenders, supersedes Penal Code section 1170.1 with respect to sentences for in-prison offenses. In 1979, at age 19, Jenson committed first degree felony murder. He was convicted and sentenced to 25 years to life. During his first nine years of incarceration, he committed three in-prison felonies: escape, possession of a weapon, and assault with a deadly weapon on an officer. The assault occurred when he was 29 years old. He received additional time for the in-prison crimes. Jenson was found suitable for parole…

View Full Summary
Name: In re Williams
Case #: B286241
District 2 DCA
Division: 2
Opinion Date: 06/20/2018

A youth offender granted parole under Penal Code section 3051 is not required to serve a consecutive sentence for an in-prison offense committed after age 25. In 1991, at age 21, Williams was convicted of first degree murder and was sentenced to 28 years to life. At age 26, he committed an in-prison battery, for which he was sentenced to an additional 8-year consecutive sentence. Williams was found suitable for parole in 2016, but the state held him to serve additional time for the in-prison offense. He filed a petition for writ of habeas corpus, arguing…

View Full Summary