California v. Sledge
Annotate this CaseDefendant Derrick Sledge appealed an order denying his petition for resentencing under one of the statutes that was enacted in 2014 as part of the Safe Neighborhoods and Schools Act (Proposition 47). The trial court found defendant’s record contained a 1980 felony forcible rape juvenile adjudication and ruled it was a disqualifying prior conviction under section 1170.18(i). After its review, the Court of Appeal concluded: (1) substantial evidence supports the court’s historical factual finding that defendant suffered the felony forcible rape juvenile adjudication; (2) some felony juvenile adjudications are disqualifying “prior convictions” for purposes of section 1170.18(i); and (3) defendant’s felony forcible rape juvenile adjudication is a disqualifying prior conviction under section 1170.18(i). Accordingly, the Court of Appeal affirmed.
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