California v. Law
Annotate this CaseIn 2001, appellant Terrell Law and his codefendant Brett May committed a home invasion robbery, during which one of them shot and killed one of the residents. They were tried jointly in 2006 before two separately empaneled juries who found them both guilty of first degree felony murder with the special circumstance described in Penal Code section 190.2(a)(17(A) and (d). Though Law's jury found he was not the shooter, they nonetheless concluded he was a "major participant" in the underlying robbery and acted "with reckless indifference to human life." In 2018, the Legislature enacted Senate Bill No. 1437 (2017-2018 Reg. Sess.) which, among other things, amended the definition of felony murder in Penal Code section 189. The legislation also added Penal Code section 1170.95, which established a procedure for vacating murder convictions predating the amendment that could not be sustained under the new definition of felony murder. Law challenged the trial court’s summary denial of his section 1170.95 petition to vacate his murder conviction, arguing the trial court erred by reviewing his record of conviction and determining the jury’s true finding on the special circumstance rendered him ineligible for relief. The Court of Appeal concluded it was proper for a trial court to review the record of conviction when determining whether a section 1170.95 petitioner had stated a prima facie claim for relief. Additionally, the Court concluded Law "undoubtedly qualifies" as a major participant who acted with reckless indifference to human life, a conclusion that rendered him ineligible for relief under section 1170.95. The Court therefore affirmed the order denying his petition.
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