California v. Superior Court (Gooden)
Annotate this CaseUnder the felony-murder rule as it existed prior to Senate Bill 1437 (Stats. 2018, ch. 1015, eff. Jan. 1, 2019), a defendant who intended to commit a specified felony could be convicted of murder for a killing during the felony, or attempted felony, without further examination of his or her mental state. Independent of the felony-murder rule, the natural and probable consequences doctrine rendered a defendant liable for murder if he or she aided and abetted the commission of a criminal act (a target offense), and a principal in the target offense committed murder (a nontarget offense) that, even if unintended, was a natural and probable consequence of the target offense. Senate Bill 1437 restricted the application of the felony murder rule and the natural and probable consequences doctrine, as applied to murder, by amending Penal Code section 189. Real parties in interest Allen Gooden and Marty Dominguez were convicted of murder in unrelated proceedings: Gooden was convicted of first degree felony murder in 1982 for the death of a neighbor during a burglary; Dominguez was found guilty of second degree murder in 1990 after a companion killed a pedestrian under facts suggesting the jury may have relied on the natural and probable consequence doctrine. Real parties in interest filed petitions requesting vacatur of their murder convictions and resentencing. The State moved to dismiss the petitions on grounds that Senate Bill 1437, which voters did not approve, impermissibly amended two voter-approved initiatives, Proposition 7 and Proposition 115. According to the State, these alleged amendments were unconstitutional. The trial court consolidated real party in interests' cases and denied the motions. The court found Senate Bill 1437 did not amend Proposition 7 because it did "not reduce sentences for first or second degree-murder." Further, the court found Senate Bill 1437 did not amend Proposition 115 because it did not "in any way modif[y]" the predicate offenses on which first degree felony-murder liability may be based. Therefore, the court found Senate Bill 1437 was not an invalid legislative amendment. Like the trial court, the Court of Appeal concluded Senate Bill 1437 was not an invalid amendment to Proposition 7 or Proposition 115 because it neither added to, nor took away from, the initiatives. Therefore, the State's petitions for writ relief were denied.
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