The California Court of Appeal has reversed the murder conviction of Daniel Anthony Cowie, allowing him to seek resentencing under new legal standards. This decision affects Cowie, who was convicted in 2009 of second-degree murder and sentenced to 40 years in prison. The ruling is significant as it reflects changes in California law regarding how murder liability is determined, particularly for those who may not have directly committed a murder.

Cowie was originally convicted in 2009 for two counts of second-degree murder. The jury found that a principal had personally discharged a firearm, resulting in great bodily injury and death. Cowie's conviction was affirmed in a previous appeal in 2011. However, in 2022, he filed a petition for resentencing under Penal Code section 1172.6, which allows individuals convicted of murder to seek relief based on changes to the law that restrict culpability for murder.

The trial court denied Cowie's petition, ruling that he was ineligible for relief because the jury instructions did not allow for a theory of liability that required malice to be imputed to him. Cowie appealed this decision, and the Court of Appeal initially upheld the trial court's ruling. However, the California Supreme Court later granted review and instructed the appellate court to reconsider the case in light of a related ruling in People v. Lopez.

Background

The parties involved in this case are the People of the State of California, represented by Attorney General Rob Bonta, and Daniel Anthony Cowie, the defendant. Cowie was convicted of second-degree murder in 2009, which was affirmed in a previous appeal. The dispute arose when Cowie filed a petition in 2022 seeking resentencing under the amended laws that had changed the standards for murder liability.

In Cowie's case, the jury found that he was guilty based on the theory that he aided and abetted the principal who committed the murder. However, the laws regarding murder liability changed in 2018 and 2021 with the enactment of Senate Bill No. 1437 and Senate Bill No. 775. These laws aimed to limit the application of murder liability to individuals who acted with malice aforethought or were major participants in the underlying felony.

The Ruling

The Court of Appeal ruled in favor of Cowie, reversing the trial court's decision and allowing for the possibility of resentencing. The court stated, "We conclude that a section 1172.6 petition may be denied at the prima facie stage only where the jury instructions, considered as a whole and together with the rest of the record of conviction, conclusively and unambiguously establish the defendant is ineligible for relief." The judges involved in this ruling were Justice Chavez, Presiding Justice Lui, and Justice Goorvitch.

In its opinion, the court emphasized that the jury instructions in Cowie's case did not clearly establish that the jury could not have convicted him based on an invalid theory of imputed malice. The court found that the instructions left room for ambiguity regarding whether the jury could have relied on a now-invalid theory of murder liability.

Impact

This ruling has significant implications for Cowie and others in similar situations. It allows Cowie to proceed with a hearing for resentencing, which could potentially reduce his lengthy prison term. The decision also sets a precedent for how courts will evaluate similar cases under the new legal standards established by recent legislative changes.

As the court noted, the changes brought by Senate Bill No. 1437 and Senate Bill No. 775 aim to ensure that individuals are not held liable for murder unless they acted with malice or were directly involved in the commission of the crime. This ruling reinforces the importance of clear jury instructions and the necessity for courts to consider the implications of legislative changes on past convictions.

What's Next

The case will now return to the trial court, which is directed to issue an order to show cause and hold an evidentiary hearing regarding Cowie's eligibility for resentencing. This development opens the door for Cowie to potentially receive a reduced sentence based on the new legal standards. It remains unclear whether the prosecution will appeal this ruling or if any related cases are pending.