Unreported / Non-Citable
Background
A Welfare and Institutions Code section 602 petition filed on March 25, 2024 alleged that A.L. committed first degree murder and personally and intentionally discharged a firearm, proximately causing great bodily injury and death. The People also sought to transfer A.L., who was 16 when the offense occurred, to criminal court. After briefing, the juvenile court filed an order denying transfer on March 18, 2025, finding him amenable to treatment and rehabilitation within the juvenile system.
The opinion recounts evidence presented in connection with the May 2023 shooting of Jeremy A. Witness accounts described A.L. and others arriving with firearms and wearing black clothing and ski masks. Cody B. said he saw A.L. shoot Jeremy, and investigators later recovered firearms-related evidence during searches. The parties stipulated that Jeremy died from multiple gunshot wounds, but also that the firearms and projectile examinations did not conclusively show that A.L. fired the fatal shot.
Following a contested jurisdictional hearing on February 19, 2026, the juvenile court found the first degree murder allegation true. It found not true the enhancement under Penal Code section 12022.53, subdivision (d), but found true the personal and intentional firearm-discharge allegation under subdivision (c). At the March 25, 2026 dispositional hearing, the court declared A.L. a ward and committed him to Pathways to Success Secure Youth Treatment Facility with a seven-year baseline term, while ordering that physical confinement could not exceed 45 years to life. A.L. timely appealed.
The Court’s Holding
Appointed appellate counsel filed a brief under People v. Wende and Anders v. California. Counsel identified potential issues concerning whether the juvenile court abused its discretion by committing A.L. to Pathways without substantial evidence that less restrictive alternatives could meet his mental health needs, and whether the court prejudicially erred by admitting Conner T.’s statements from a Perkins operation. The Court of Appeal also gave A.L. an opportunity to submit a personal supplemental brief, but he did not do so.
The court explained that Wende review requires examination of the entire record for issues that, if resolved favorably to the appellant, would produce reversal or modification. After independently examining the record under Wende and People v. Kelly, the court found no arguable errors favorable to A.L. It therefore affirmed the judgment rather than resolving either potential issue in his favor or altering the juvenile court’s disposition.
The disposition states simply that the judgment is affirmed. The opinion was filed October 6, 2026, in appeal E088436 from Riverside County Superior Court case DLIN2400041, and is marked not to be published in official reports.
Key Takeaways
- Independent review of the entire appellate record revealed no arguable issue that would support a disposition more favorable to A.L.
- The affirmed judgment includes the true finding on first degree murder and the firearm enhancement under Penal Code section 12022.53, subdivision (c).
- The juvenile court had rejected the separate enhancement alleged under section 12022.53, subdivision (d), and had earlier filed an order denying the prosecution’s request to transfer A.L. to criminal court.
- Counsel’s identification of possible placement and evidentiary issues did not lead the appellate court to find reversible error after its Wende review.
- A.L. did not file a personal supplemental brief after receiving an opportunity to do so.
Why It Matters
The decision leaves intact both the juvenile court’s adjudication and its commitment order, including the seven-year baseline term at Pathways. Its appellate significance is the completion of the constitutionally grounded independent-review process used when appointed counsel finds no arguable basis for reversal: the court reviewed the record itself rather than relying solely on counsel’s no-issue brief.
The opinion does not establish a new published rule and expressly carries California’s nonpublication designation. It documents the case-specific outcome of the Wende review, including the potential issues counsel presented and the appellate court’s conclusion that none warranted relief.