People v. Watson CA2/4

INTRODUCTION AND BACKGROUND

A jury convicted defendant and appellant Shaylor Watson of robbery and two special circumstance murders, one of which he committed when he was 18 years old.1 On the murder Watson committed when he was 18 years old, the trial court sentenced him to life without the possibility of parole (LWOP) plus two years in state prison. In 2022, Watson filed a motion for proceedings preserving evidence under People v. Franklin (2016) 63 Cal.4th 261 (Franklin), in preparation for an eventual youth offender parole hearing under Penal Code section 3051.2 The trial court denied Watson relief, noting section 3051 facially does not extend to individuals who committed their offenses between the ages of 18 and 25 and received LWOP sentences. In denying relief, the court rejected Watson’s argument that section 3051, as currently construed, violates equal protection principles. Watson timely appealed. On appeal, he renews his argument, raised in the trial court, that by not extending relief to individuals who committed their offenses between the ages of 18 and 25 and received LWOP sentences, while extending relief to individuals who committed their offenses between the ages…