People v. Medrano
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Defendants Martinez and Medrano argued that the recent enactment of Senate Bill 1437 requires reversal of their attempted murder convictions because the jury instructions and the prosecutor's arguments allowed the jury to convict them on the now repudiated theory that attempted murder was a natural and probable consequence of aiding and abetting assault likely to cause bodily harm and because Penal Code section 188 no longer permits imputed malice.
In the published portion of this appeal, the Court of Appeal found no merit to the new claims pertaining to the natural and probable consequences doctrine, holding that Senate Bill 1437 abrogated the continuing application of this doctrine to murder charges. Furthermore, this change in the law applies to attempted murder charges premised on this doctrine. Accordingly, the court parted company with its sister circuits, but agreed that the petitioning procedure added in section 1170.95 does not apply to attempted murder. The court reviewed defendants' claim under In re Estrada (1965) 63 Cal.2d 740, and concluded that defendants were entitled to relief on direct appeal. Accordingly, the court reversed the judgments of conviction for attempted murder.
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