People v. Love
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Senate Bill 1437 does not eliminate the natural and probable consequences theory for attempted murder on any basis—either prospectively or retroactively.
In reaching this holding, the Court of Appeal held that (1) Senate Bill 1437's inapplicability to the crime of attempted murder on a prospective basis is not clear from its text, but is clear from its legislative history and not contradicted by any of the other canons of statutory construction, and (2) even if Senate Bill 1437 applied prospectively to the crime of attempted murder, that application would not have any retroactive effect because the bill's statutory mechanism for providing retroactive relief—namely, section 1170.95—limits relief to "convictions" for "murder," which rebuts the usual presumption that ameliorative changes in the law apply retroactively to nonfinal convictions. Therefore, the court affirmed the order denying relief under Senate Bill 1437 as well as the judgment.
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