People v. Watson CA2/1

INTRODUCTION

In 2020, defendant Samuel R. Watson was charged with murder and elder abuse causing death. In 2022, he pleaded no contest to second degree murder pursuant to a plea agreement. In 2023, Watson filed a petition for resentencing under Penal Code1 section 1172.6. The trial court denied the petition and Watson now appeals that decision. His appellate counsel filed a brief pursuant to People v. Delgadillo (2022) 14 Cal.5th 216, identifying no issues on appeal. Watson filed a supplemental brief raising certain contentions about his conviction, but none concerns the merits of his resentencing petition. The issues raised by Watson are outside the scope of a section 1172.6 resentencing proceeding and fail to demonstrate any error in the court’s denial of his petition. Accordingly, we affirm.

POSTCONVICTION RELIEF UNDER SECTION 1172.

We begin by briefly summarizing section 1172.6, which was enacted in 2018 as part of Senate Bill No. 1437 (2017-2018 Reg. Sess.).2 The legislation’s overall purpose was “to amend the felony murder rule and the natural and probable consequences doctrine, as it relates to murder, to ensure that murder liability is not imposed on a person who is…