California Court Denies Appeal of Young Adult Sentenced to LWOP

RJ Donovan Correctional Facility, where Ayala is currently incarcerated. (Layton Construction)

On December 17, 2020, a California state appellate court affirmed the decision to deny postconviction relief for Joel Ayala, who was sentenced to life without the possibility of parole (LWOP) for first-degree murder committed at age 18.

In 1986, when Ayala was 18 years old, he and another person attempted to carjack a truck. Ayala shot the owner of the truck once and the second person shot the truck owner twice. The truck owner died. Ayala was charged with and found guilty of first-degree murder and was sentenced to LWOP.

In 2019, Ayala petitioned for a writ of habeas corpus seeking a youth offender parole hearing under section 3051 of the California Penal Code. Section 3051 grants youth offender parole hearings after 25 years of incarceration to all juveniles under age 18 at the time of their offense as well as all those ages 18 to 25 at the time of their offense and sentenced to anything less than LWOP.

But, because Ayala was 18 years old at the time of his crime and sentenced to LWOP, he is not eligible for release under section 3051. Ayala contended that this section denies his right to equal protection, because it explicitly excludes those ages 18 to 25 at the time of their crimes and sentenced to LWOP. He first asserted that distinguishing between juveniles sentenced to LWOP and young adults sentenced to LWOP is unconstitutional because of young adult brain science. He then asserted that distinguishing between young adults sentenced to LWOP and young adults sentenced to lesser sentences is unconstitutional.

The court first found that distinguishing between juveniles and young adults has repeatedly been found to be rational by the U.S. Supreme Court and California Supreme Court, citing many cases and stating, “We add another brick to this stone wall of precedent.”

The court then found that distinguishing between young adults sentenced to LWOP and young adults not sentenced to LWOP is also rational, as those sentenced to LWOP have been found to have committed first-degree murder under one of 22 different aggravating circumstances. So, the groups of young adults who committed first-degree murder but were not sentenced to LWOP and young adults who committed first-degree murder and were sentenced to LWOP are not similarly situated. The court held that “the difference in the underlying crimes provides a rational reason for distinguishing between the two groups of first degree murderers.”

Accordingly, the appeals court affirmed the judgement of the trial court to deny Ayala’s youth offender parole hearing.

Citation: People v. Ayala, 2020 WL 7394960

Key words: California, Miller v. Alabama, young adult, adolescent brain, LWOP

This post is the 71st post as part of an ongoing Center for Law, Brain & Behavior (CLBB) series tracking the latest developments in law and neuroscience cases. To see previous posts about recent cases, see the full case archive on the CLBB website. To see updates on legal scholarship, see the Neurolaw News, hosted by the MacArthur Foundation Research Network on Law and Neuroscience. This project is made possible through support of the Dana Foundation.

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