People v. Paige
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Penal Code section 1170.95, which became effective in January 2019, changed the application of the felony murder and natural and probable consequences theories of murder liability. It entitles certain defendants to petition the superior court for resentencing. Paige filed such a petition, which the trial court denied, based on the fact that Paige, although he was charged with felony murder, was convicted of voluntary manslaughter via a plea agreement.
The court of appeal affirmed, rejecting arguments based on statutory interpretation and federal equal protection rights. The petitioning prerequisites and available relief indicate that the legislature intended to limit relief to those convicted of murder under a theory of felony murder or natural-and-probable consequences murder. Section 1170.95 is unambiguous and does not provide relief to persons convicted of manslaughter. It is not irrational to distinguish between those convicted of murder by plea and those convicted of voluntary manslaughter by plea.
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