People v. Williams CA4/1

A model's reading — qwen3.8-27b, prompt v1, 2026-10-13T04:58Z · confidence high

The trial court denied Williams's petition to vacate his conviction for possession of marijuana in prison under Health and Safety Code section 11361.8. The Court of Appeal affirmed the denial after conducting an independent review of the record pursuant to People v. Wende, finding no arguable issues for reversal.

Ruling reviewed	Standard	The court	The model
Denial of petition to vacate conviction under Health and Safety Code section 11361.8 “We have reviewed the entire record as mandated by Wende and Anders. We have not discovered any arguable issues for reversal on appeal.”	de novo	correct	agree with court The appellate court applied the standard de novo review required for statutory vacatur petitions. It correctly identified that the trial court's denial was supported by the record, specifically noting the stipulation that marijuana was found in the defendant's cell, which establishes the factual basis for the conviction that section 11361.8 does not automatically vacate without a showing of lack of intent or other statutory exceptions not present here. The court's reliance on the Wende/Anders framework is procedurally appropriate given the appointed counsel's brief.

Authorities

• relied: People v. Wende (1979) 25 Cal.3d 436 — Requires appointed appellate counsel to conduct an independent review of the record for error when no arguable issues are identified.
• relied: Anders v. California (1967) 386 U.S. 738 — Establishes the procedure for appointed counsel to withdraw from an appeal by filing a brief identifying potential issues and requesting court review.
• relied: People v. Raybon (2021) 11 Cal.5th 1056 — Interprets the scope of Health and Safety Code section 11361.8 regarding the vacatur of marijuana convictions.

The appellate opinion: sound — The opinion is procedurally sound as it correctly follows the Wende/Anders protocol for reviewing a record when counsel identifies no issues. It accurately applies the de novo standard to the statutory petition and relies on the correct controlling authority (Raybon) for the substantive law.

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A model's reading — claude-fable-5-1, prompt v1, 2026-10-13T04:30Z · confidence low

The trial court denied Jamell Williams's petition under Health and Safety Code section 11361.8 to vacate his 2018 no-contest conviction for possessing marijuana in prison (Pen. Code, § 4573.6). On appeal, appointed counsel filed a Wende brief, Williams filed nothing, and the Court of Appeal independently reviewed the record, found no arguable issue, and affirmed.

Ruling reviewed	Standard	The court	The model
Denial of petition under Health and Safety Code section 11361.8 to vacate a Penal Code section 4573.6 conviction for possession of marijuana in prison “Did the trial court err in denying Williams’s petition, (People v. Raybon (2021) 11 Cal.5th 1056).”	unclear	correct	agree with court The only potential issue counsel flagged is governed directly by People v. Raybon, where the Supreme Court held that Proposition 64 did not legalize possession of cannabis in prison and that section 4573.6 convictions remain valid. Because section 11361.8 relief depends on the conduct no longer being an offense after Proposition 64, Raybon forecloses the petition, and the affirmance follows.

Authorities

• relied: People v. Wende (1979) 25 Cal.3d 436 — When appointed appellate counsel finds no arguable issues, the Court of Appeal must independently review the entire record for error.
• relied: Anders v. California (1967) 386 U.S. 738 — Appointed counsel who finds an appeal frivolous should identify anything in the record that might arguably support the appeal to assist the court's review.
• relied: People v. Raybon (2021) 11 Cal.5th 1056 — Proposition 64 did not decriminalize possession of cannabis in prison; Penal Code section 4573.6 continues to apply, so such convictions are not subject to vacatur under Health and Safety Code section 11361.8.

The appellate opinion: sound — The court applied the Wende/Anders procedure, identified the single plausible issue, and the controlling Supreme Court decision in Raybon squarely forecloses relief, so the affirmance is correct. The opinion does not discuss whether Wende review is even required for an appeal from a postconviction petition, but conducting the review was more protective of the appellant and does not affect the result.

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