People v. Strong
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The Supreme Court reversed the decision of the court of appeal affirming the judgment of the trial court denying Appellant's petition for resentencing under Senate Bill No. 1437, holding that certain special circumstance findings did not preclude him from making out a prima facie case for resentencing.
In 2014, Appellant was convicted of felony murder. The jury found true felony-murder special-circumstance allegations that Appellant was a "major participant" who acted with "reckless indifference to human life" under Cal. Penal Code 190.2, subdivision (d). Thereafter, the Supreme Court decided People v. Banks, 61 Cal. 4th 788 (2015) and People v. Clark, 63 Cal.4th 522 (2016), which provided guidance on the meaning of the statutory phrases "major participant" and "with reckless indifference to human life." In 2018, the Legislature adopted Senate Bill 1437. Appellant then petitioned for resentencing. The trial court denied the petition. The Supreme Court reversed, holding (1) findings issued by a jury before Banks and Clark do not preclude a defendant from making out a prima facie case for relief under Senate Bill 1437; and (2) because Appellant's case was tried before both Banks and Clerk, the special circumstance findings did not preclude him from making out a prima facie case for resentencing under section 1172.6.
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