California v. Lamoureux
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. Patty Ann Lamoureux appealed an order denying her petition to vacate a first degree murder conviction and obtain resentencing under the procedures established by Senate Bill 1437. The trial court denied the petition after concluding the resentencing provision of Senate Bill 1437 invalidly amended Proposition 7, a voter initiative that increased the punishments for persons convicted of murder. The State urged the Court of Appeal to affirm the denial order on grounds that: (1) Senate Bill 1437 invalidly amended Proposition 7; (2) Senate Bill 1437 invalidly amended Proposition 115, a voter initiative that augmented the list of predicate offenses for first degree felony-murder liability; (3) the resentencing provision violated the separation of powers doctrine; and/or (4) the resentencing provision deprived crime victims the rights afforded them by the Victims' Bill of Rights Act of 2008 (Marsy's Law). In California v. Superior Court (Gooden), ___ Cal.App.5th ___ (Nov. 19, 2019, D075787) a companion case issued with this case, the Court of Appeal concluded Senate Bill 1437 did not invalidly amend Proposition 7 or Proposition 115. Like the Gooden opinion, the Court reached the same determination here. Further, the Court concluded the resentencing provision of Senate Bill 1437 did not contravene separation of powers principles or violate the rights of crime victims. Therefore, the Court found "no constitutional infirmity" with Senate Bill 1437, and reversed the order denying Lamoureux's petition.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.