People v. Clayton
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Appellant appealed the summary denial of his petition to vacate his 2000 murder conviction and for resentencing pursuant to Penal Code section 1170.95. The parties agree that the superior court's denial of the petition was in error. At issue is whether a jury's not true finding on a felony-murder special-circumstance allegation constitutes "a prior finding by a . . . jury that the petitioner did not act with reckless indifference to human life or was not a major participant in the [underlying] felony," thus triggering the superior court's duty to vacate the murder conviction and resentence the petitioner under section 1170.95, subdivision (d)(2)?
The Court of Appeal held that the jury's unanimous rejection of the special-circumstance allegation establishes the petitioner's entitlement to relief under section 1170.95 as a matter of law. In this case, appellant stated a prima facie case for relief under section 1170.95, and the superior court's summary denial of the petition based on its own findings of fact violated the statutory procedures mandated under section subdivisions 1170.95(c) and (d). The court explained that the superior court is required to vacate the murder conviction and resentence appellant based on the jury's unanimous finding beyond a reasonable doubt that the special-circumstance allegation was not true. Therefore, the court reversed the order denying the petition and remanded to the superior court with directions to grant the petition, vacate appellant's murder conviction, and resentence him on the remaining counts.
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