California’s Supreme Court has ordered lower courts to reconsider the sentence of Richard Morris Jr., who was convicted in 2013 for a murder that occurred on January 1, 1987. The ruling centers on recent changes to state law regarding accomplice liability in murder cases.
Morris was found guilty of first-degree murder in the death of James Stockwell, a bar owner who was killed during a robbery at his residence. The incident occurred when Morris and an accomplice confronted Stockwell and his girlfriend as they returned home late at night. During the violent encounter, both victims were forced to lie down while the perpetrators demanded money and jewelry.
The attackers took both victims upstairs, where they sexually assaulted Stockwell’s girlfriend before restraining her. They told her they were taking Stockwell to his business establishment. After the men departed in Stockwell’s vehicle, the girlfriend discovered that Stockwell had been shot. She sought help from a neighbor, but when she returned, Stockwell had died from a single gunshot wound to the head.
The case remained unsolved for decades until technological advances allowed investigators to analyze DNA evidence collected from the girlfriend at the time of the crime. Testing conducted in 2009 and 2012 matched the DNA samples to Morris, leading to his arrest and charges in December 2011.
In 2013, more than 25 years after the crime, a jury convicted Morris of first-degree murder with special circumstances including rape, robbery, and murder for financial gain. He received a sentence of life imprisonment without the possibility of parole, plus five years. An appeals court upheld his conviction in 2015.
The current legal challenge stems from Senate Bill 1437, enacted in September 2018, which significantly narrowed the circumstances under which accomplices can be held liable for murder. Under the revised law, individuals who did not personally kill the victim can only be convicted of murder if they either aided the actual killer with intent to kill or were major participants in the underlying felony while acting with reckless indifference to human life.
Morris filed a petition in 2022 arguing that under the new legal standard, he could not be convicted of first-degree murder because he did not directly aid in the lethal act that killed Stockwell. The Orange County Superior Court denied his petition, and an appellate panel upheld that denial in March 2024.
In the Supreme Court’s majority opinion, Justice Joshua Groban interpreted the statute to require proof that a defendant aided the actual killer in the lethal act itself, not merely in the underlying felony. The court found that the most natural reading of the law suggests that aiding ‘the actual killer’ means assisting with the lethal act rather than helping someone who eventually commits murder during a separate felonious act.
Chief Justice Patricia Guerrero wrote a concurring opinion, stating that while she disagreed that the statutory language was unambiguous, she supported adopting the interpretation most favorable to the defendant. A dissenting opinion argued that the court should not overturn 175 years of felony-murder precedent based on ambiguous statutory language.
The Supreme Court reversed the appellate court’s decision and sent the case back for reconsideration. If the lower court determines Morris’s resentencing request has merit, an evidentiary hearing will be held to determine whether he qualifies for relief under the amended law.
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