People v. York
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The trial court agreed with the parties that Penal Code section 1170.95 and Senate Bill 1437 are not unconstitutional. In the published portion of the opinion, the court held that trial counsel was required to appoint counsel to defendant before ruling on his petition. In this case, the record provides no basis for determining that defendant was precluded from showing that he was not a major participant in the robbery and did not act with reckless indifference to human life.
The court held that the jury's special circumstance finding, affirmed in 1996, approximately two decades before People v. Banks (2015) 61 Cal.4th 788, and People v. Clark (2016) 63 Cal.4th 522, were decided, does not preclude defendant from relief as a matter of law. The court explained that a pre-Banks and Clark special circumstance finding cannot preclude eligibility for relief under section 1170.95 as a matter of law, because the factual issues that the jury was asked to resolve in a trial that occurred before Banks and Clark were decided are not the same factual issues the Supreme Court has since identified as controlling. Furthermore, the court did not find recent authority to the contrary persuasive. Accordingly, the trial court reversed the order denying defendant's resentencing petition and remanded.
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