People v. Daniel
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In 2015, a jury convicted Daniel of second-degree murder in the death of his girlfriend. He was sentenced to 15 years to life in prison. In 2018, Senate Bill 1437 altered liability for murder under the theories of felony murder and natural and probable consequences and established a procedure, Penal Code section 1170.95, for eligible defendants to seek resentencing. Daniel filed a petition for relief, alleging that he was convicted of murder under the natural and probable consequences doctrine or the felony murder doctrine and could no longer be convicted of murder because of Senate Bill 1437’s changes to the law.
The trial court summarily denied the petition, reasoning that the jury was not instructed on either theory of liability and the record showed Daniel was the actual killer. The court of appeal affirmed. Although the judge who ruled on the petition failed to appoint counsel and was not the sentencing judge, both violations of section 1170.95, the errors were harmless. A court’s failure to appoint counsel after a petitioner files a facially sufficient petition for relief is not prejudicial error when records in the court’s own file—here, the jury instructions— demonstrate that the petitioner is ineligible for relief as a matter of law.
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