P. v. Estrada
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Petitioner was convicted of first-degree murder in 2010. The jury also found that Petitioner committed the offense within the meaning of the gang enhancement (Cal. Penal Code Sec. 186.22(b)(1)(C)). However, the jury rejected the firearm enhancements. In 2019, Petitioner filed a petition for resentencing citing Senate Bill 1437 ("SB 1437"), claiming he was not the actual killer, did not act with the intent to kill, and was not a major participant in the underlying felony who acted with reckless indifference to human life. The trial court denied relief, finding that Petitioner was convicted under a theory of aiding and abetting.
The Second Appellate District affirmed the trial court's denial of Petitioner's SB 1437 petition for resentencing. At trial, the jury was instructed that it could only find Petitioner guilty of first-degree murder if it "concluded he acted willfully and with intent to kill." Thus, by finding Petitioner guilty of murder, the jury necessarily found he acted with the intent to kill. Further, the trial court did not instruct the jury on the natural and probable consequences doctrine. Because SB 1437 amended the felony murder law only as it pertains to the natural and probable causes doctrine, Petitioner was not entitled to relief.
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