Jul. 11, 2022 – People v. Zabelle (3rd Dist., C093173)

The Court of Appeal holds that defendant’s statements to police were voluntary and not induced by a promise of leniency where officers said that early cooperation could be beneficial in an unspecified way and also that it could work in the defendant’s favor to be honest and admit involvement. As to defendant’s request for resentencing based on SB 567, the court applies both the Chapman and Watson standards to assess prejudice, finding the error harmless under Chapman but requiring reversal as a state law error.