People v. Valencia
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Defendant appealed the trial court's denial of his second petition for recall of sentence pursuant to the Three Strikes Reform Act of 2012 under Penal Code, section 1170.126. Defendant contends that his rehabilitative progress in prison constitutes good cause to permit the untimely and successive petition.
The Court of Appeal concluded that it need not resolve whether the Three Strikes Reform Act permits an inmate to file successive recall petitions because, even assuming it does, an inmate's rehabilitative progress does not constitute good cause to excuse an untimely filing. The court explained that the language and structure of the statute do not permit a showing that rehabilitative progress constitutes good cause to permit an otherwise untimely successive petition, and the history of the law confirms the voters did not intend to permit such filing. Therefore, the court concluded that the trial court properly denied the petition and the court affirmed the judgment.
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