# People v. Lawson CA2/3

> California Court of Appeal · December 1, 2025

URL: https://www.frixlaw.com/law-library/cases/11211901

## Case

- **Court:** California Court of Appeal
- **Decided:** December 1, 2025
- **Precedential status:** Unpublished
- **Opinion:** Opinion
- **Cited by:** 0 later opinions in the Frix Law Library

## Citator (automated)

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## Opinion text

Filed 12/1/25 P. v. Lawson CA2/3
NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS

California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions
not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion
has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION THREE

THE PEOPLE, B338790

Plaintiff and Respondent, (Los Angeles County
Super. Ct. No. TA145980)
v.

KARNELL SEAN LAWSON,

Defendant and Appellant.

APPEAL from an order of the Superior Court of
Los Angeles County, Ricardo Ocampo, Judge. Reversed and
remanded.
Sylvia W. Beckham, under appointment by the Court of
Appeal, for Defendant and Appellant.
Rob Bonta, Attorney General, Charles C. Ragland, Chief
Assistant Attorney General, Susan Sullivan Pithey, Assistant
Attorney General, Noah P. Hill and Kathy S. Pomerantz, Deputy
Attorneys General, for Plaintiff and Respondent.
‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗

MEMORANDUM OPINION1
Defendant and appellant Karnell Sean Lawson appeals
from an order denying his petition for resentencing under Penal
Code section 1172.6.2 The People concede, and we agree, that the
trial court erred in concluding Lawson was ineligible for relief
solely because he pled guilty to attempted murder after the
effective date of Senate Bill No. 1437. We reverse and remand.
BACKGROUND
In October 2018, the People filed an information charging
Lawson and six codefendants in connection with shootings that
took place on August 4, 2016. The information charged all
defendants with special circumstances murder (§§ 187, subd. (a),
190.2, subd. (a)(21), (22); count 1); three counts of attempted
murder (§§ 664, 187, subd. (a); counts 2, 3, 5); shooting at an
occupied vehicle (§ 246; count 4); and shooting at an inhabited
dwelling (§ 246; count 6). The information alleged gang
enhancements (§ 186.22, subd. (b)) and firearm enhancements
(§ 12022.53, subds. (d), (e)) as to each count. Lawson and his
codefendants were alleged to have shot at multiple victims, some
of whom were rival gang members, from a “multi-car caravan.”

1 We resolve this matter by memorandum opinion, consistent
with California Standards of Judicial Administration, section 8.1.
(People v. Garcia (2002) 97 Cal.App.4th 847, 850–855.)

2 Further undesignated statutory references are to the Penal
Code.

2
In November 2019, the People and Lawson entered into an
immunity and plea agreement affording Lawson leniency in
exchange for his truthful testimony in other prosecutions.
Pursuant to the agreement, Lawson pled guilty to all counts in
the information and to an additional count of voluntary
manslaughter. As to all counts, Lawson also admitted principal
use of a firearm enhancements under section 12022.53,
subdivisions (c), (d), and (e)(1).
In February 2020, the trial court concluded Lawson had
completed his testimonial obligations. Pursuant to the plea
agreement, Lawson withdrew his pleas to counts 1, 4, and 6 and
pled guilty to the attempted murder and voluntary manslaughter
counts only. The court sentenced Lawson to an aggregate term of
28 years: 11 years for the voluntary manslaughter conviction, 10
years on the firearm enhancement for voluntary manslaughter,
and the midterm of two years and four months on each of the
three attempted murder convictions.
On January 1, 2019, Senate Bill No. 1437 (2017–2018 Reg.
Sess.) (Senate Bill No. 1437) eliminated the natural and probable
consequences doctrine as a basis for murder and limited the scope
of the felony murder rule. (Stats. 2018, ch. 1015, § 1, subd. (f).)
In October 2020, Lawson filed a form petition for resentencing
under former section 1170.95, now section 1172.6. The trial court
denied the petition because Lawson entered his plea after Senate
Bill No. 1437 took effect, and because Lawson was not convicted
of murder, which was the sole offense qualifying for resentencing
relief under the statute at the time. A different panel of this
division affirmed the trial court’s order. (People v. Lawson (July
9, 2021, B309899) [nonpub. opn.].)

3
On January 1, 2022, Senate Bill No. 775 (2021–2022 Reg.
Sess.) (Senate Bill No. 775) further amended the Penal Code to
eliminate the natural and probable consequences doctrine as a
theory of liability for attempted murder. (§ 1172.6, subd. (a).)
Less than two weeks later, Lawson filed a second form petition
for resentencing pursuant to section 1172.6. The People conceded
that Lawson’s petition made a prima facie showing of eligibility.
The court issued an order to show cause and prepared to set the
matter for an evidentiary hearing.
However, in May 2024, relying on People v. Reyes (2023) 97
Cal.App.5th 292 (Reyes), the trial court vacated its order to show
cause. The court denied Lawson’s petition after concluding he
was ineligible for resentencing because he entered his plea after
Senate Bill No. 1437’s amendments to the Penal Code became
effective. Lawson timely appealed.
DISCUSSION
Lawson contends the trial court erred in concluding he was
ineligible for section 1172.6 relief solely because he pled guilty to
attempted murder after the effective date of Senate Bill No. 1437.
The People concede the error, and we agree.
Lawson’s 2019 plea did not categorically preclude him from
establishing prima facie eligibility for section 1172.6 resentencing
as to his attempted murder convictions. Unlike the defendant in
Reyes, who sought resentencing on a murder conviction that was
the result of a plea he entered after Senate Bill No. 1437
amended the law (Reyes, supra, 97 Cal.App.5th at p. 296),
Lawson seeks resentencing on attempted murder convictions.
Although Lawson entered his plea after Senate Bill No. 1437’s
effective date, the law was unsettled at the time as to whether
Senate Bill No. 1437’s amendments to section 188 applied to

4
attempted murder. (Compare People v. Flores (2020) 44
Cal.App.5th 985, 993–994 [finding Sen. Bill No. 1437 limited
relief to defendants convicted of murder] with People v. Sanchez
(2022) 75 Cal.App.5th 191, 193 [describing previous conclusion,
before passage of Sen. Bill No. 775, that Sen. Bill No. 1437
eliminated natural and probable consequences doctrine for
attempted murder].) This question was not resolved until 2022,
when Senate Bill No. 775 expressly extended resentencing relief
to defendants convicted of attempted murder on a natural and
probable consequences theory. (Sanchez, at p. 196.) When
Lawson pled guilty to attempted murder in 2019, it was still
possible that he could have been convicted of attempted murder
based on the natural and probable consequences doctrine. The
date of his plea therefore does not render him ineligible for
resentencing relief under section 1172.6 as a matter of law.
Further, as the People concede, the record of conviction
does not eliminate the possibility that the People could have
prosecuted Lawson for attempted murder under the natural and
probable consequences doctrine. (People v. Gaillard (2024) 99
Cal.App.5th 1206, 1211.) The record of conviction here consists of
the information, the preliminary hearing transcript, and the
transcript of the plea hearing. Lawson was charged with several
codefendants who were also alleged to have shot at the victims.
The People concede that “[n]othing in the preliminary hearing
transcript necessarily rules out the possibility that the
prosecution could have prosecuted [Lawson] under the natural
and probable consequences doctrine. . . . [T]he evidence does not
appear to suggest that the prosecution absolutely was going to
limit itself, or had to plausibly limit itself, to an actual shooter
theory if the case went to trial based on the case it presented at

5
the preliminary hearing.” We agree. Lawson established his
prima facie eligibility for section 1172.6 relief as to his attempted
murder convictions.
However, to the extent Lawson asks this court to reverse
the trial court’s order with respect to his voluntary manslaughter
conviction, we reject the request.
Senate Bill No. 775 added manslaughter to section 1172.6,
but only to clarify that persons “ ‘convicted of manslaughter when
the prosecution was allowed to proceed on a theory of felony
murder or murder under the natural and probable consequences
doctrine . . . [may] apply to have their sentence vacated and be
resentenced.’ ” (People v. Lezama (2024) 101 Cal.App.5th 583,
590, italics added, quoting Sen. Com. on Public Safety, Rep. on
Sen. Bill No. 775 (2021–2022 Reg. Sess.) as amended Feb. 19,
2021, p. 3.) As explained in Lezama and People v. Gallegos (2024)
105 Cal.App.5th 434, 443, defendants who pled guilty to
voluntary manslaughter after Senate Bill No. 1437 eliminated
imputed malice theories for murder cannot show they could have
been convicted of murder under an invalid theory. (See Reyes,
supra, 97 Cal.App.5th at p. 299.) Indeed, Lawson concedes on
appeal that Lezama and Gallegos “might preclude relief on
Lawson’s conviction for voluntary manslaughter as the record
now stands based on Lawson’s checkbox form petition and the
date of his plea.”
Lawson nonetheless requests that we remand to provide
him an opportunity to introduce “additional facts,” relying on
People v. Patton (2025) 17 Cal.5th 549. Yet, Lawson’s ineligibility
for relief is based on the date of his plea, a fact he cannot dispute.
No additional facts would make Lawson eligible for resentencing
on his voluntary manslaughter conviction, and his reliance on

6
Patton is misplaced. (See People v. Medrano (2024) 98
Cal.App.5th 1254, 1264 [law of the case barred successive appeal
from denial of § 1172.6 petition because no new evidence would
change legal conclusion in previous opinion].)
DISPOSITION
The trial court’s May 24, 2024, order denying Lawson’s
petition for resentencing is reversed. The matter is remanded for
issuance of an order to show cause and an evidentiary hearing
pursuant to section 1172.6 on Lawson’s attempted murder
convictions.
NOT TO BE PUBLISHED IN THE OFFICIAL
REPORTS

ADAMS, J.

We concur:

EDMON, P. J.

EGERTON, J.

7

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11211901. Public record. Not legal advice.