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Name: People v. Superior Court (Williams)
Case #: H051569
Court: CA Court of Appeal
District 6 DCA
Opinion Date: 06/24/2024

The Court of Appeal holds that applying the revised penalty provisions of the Three Strikes Reform Act to reduce a defendant’s indeterminate life term to a determinate term when the defendant is being resentenced under PC 1172.75 due to an invalid prior prison term enhancement unconstitutionally amends the resentencing procedure and requirements set forth in PC 1170.126 of the voter-approved Three Strikes Reform Act. The concurring/dissenting opinion agrees that defendant’s application of PC 1172.75 would constitute an impermissible amendment to the Three Strikes Reform Act, but concludes that a reasonable construction of PC 1172.75 and PC 1170.126 harmonizes both statutes while preserving the voters’ intent to protect public safety by giving judges the discretion to determine the risk of danger posed by resentencing. [Editor’s Note: The following issue is pending before the California Supreme Court in People v. Superior Court (Guevara) (2023) 97 Cal.App.5th 978, review granted 3/12/2024 (S283305/B329457): Do the revised penalty provisions of the Three Strikes Reform Act of 2012 (Pen. Code, § 1170.12) apply when a defendant is resentenced pursuant to Senate Bill No. 483 (Pen. Code, § 1172.75)?]

The full opinion is available on the court’s website here: