People v. Padilla
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The Supreme Court held that Proposition 57, a measure that amended the law governing the punishment of juvenile offenses in adult criminal court by requiring hearings to determine whether the offenses should instead by hearing in juvenile court, applied during resentencing where the criminal court sentence imposed on Defendant, a juvenile offender, was issued before the initiative's passage but was since vacated.
Defendant was originally sentenced before Proposition 57 was enacted, but his sentence was later vacated on habeas corpus, and the case was returned to the trial court for imposition of a new sentence. At issue was whether Proposition 57 applied to Defendant's resentencing. The Supreme Court affirmed the judgment of the court of appeal, holding that Proposition 57 applied to Defendant's resentencing because the judgment in his case became nonfinal when his sentence was vacated on habeas corpus.
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