In a significant ruling, the California Court of Appeal upheld the resentencing of Ryan Paul McAlister, affirming the application of new sentencing laws that impact how defendants are sentenced after having previously accepted plea deals. This decision affects not only McAlister but also sets a precedent for other defendants who may find themselves in similar situations regarding their sentences.
The case, officially titled People v. McAlister, was filed under docket number G064690 on August 7, 2026. The court's ruling clarifies how certain amendments to California's sentencing laws apply to defendants who have already been sentenced, particularly in cases where the upper term of a sentencing triad was imposed.
McAlister's legal journey began in 2014 when he pleaded guilty to multiple charges, including attempted murder and shooting at an occupied vehicle. As part of a plea deal, he accepted a stipulated sentence of 25 years in prison, which included the upper term of nine years for attempted murder. However, in 2024, McAlister was resentenced under California Penal Code section 1172.75, which allows for the retroactive dismissal of certain prison enhancements. This resentencing reduced his total sentence to 23 years and 4 months.
The central issue in McAlister's appeal was whether the new laws regarding the imposition of upper terms applied to his case. Specifically, the court had to determine if the changes made to Penal Code section 1170, which require a jury to find aggravating circumstances before an upper term can be imposed, would affect McAlister's resentencing. The court ultimately concluded that the new laws did not apply to McAlister because he had originally been sentenced to the upper term.
Judge Sanchez, writing for the court, stated, "Section 1172.75, subdivision (d)(4), mirrors the conditions imposed by section 1170, subdivision (b), except it adds the following caveat: 'Unless the court originally imposed the upper term...'." This means that since McAlister had already received the upper term, the court could reimpose it without needing a new jury finding or stipulation from him.
The court's ruling also addressed an argument from McAlister regarding equal protection under the law. He contended that the interpretation of section 1172.75 violated the Equal Protection clause because it treated defendants resentenced under different statutes differently. The court found that the Legislature had reasonable grounds for this distinction, noting that the administrative burden of revisiting every upper term sentence would be significant. The court stated, "The Legislature could have reasonably concluded that it would have been too costly and time-consuming to revisit every upper term sentence pursuant to section 1170, subdivision (b)."
This ruling is significant as it clarifies how California courts will handle resentencing under the new laws. It means that defendants who were originally sentenced to the upper term may not benefit from the new jury finding requirements that apply to others. This decision could affect many individuals who are currently serving sentences that include upper terms, as it sets a precedent for how the courts interpret these laws moving forward.
Looking ahead, McAlister's case may not be the last word on this issue. While the court affirmed the judgment, it is possible that McAlister or other defendants could seek further review or appeal to the California Supreme Court. Additionally, there may be related cases pending that could further clarify the application of these new laws and their implications for defendants across the state.