On August 8, 2022, the California Supreme Court decided a long-awaited case that affects SB 1437 Petitions for individuals convicted of Special Circumstance Murder when they ruled in the case of People v. Christopher Strong. Specifically, the Supreme Court ruled that some special circumstance findings do not automatically preclude defendants from SB 1437 relief.
Background Regarding SB 1437
In 2019, SB 1437 was enacted, amending Penal Code § 188 and § 189 and creating Penal Code § 1170.95. Pursuant to SB 1437, accomplice liability for felony murder and murder by way of the natural and probable consequence doctrine was substantially changed, allowing individuals convicted to seek to vacate their murder convictions and obtain resentencing relief. Resentencing is available for individuals convicted of murder, attempted murder, and/or manslaughter if they demonstrate: