High Court

Trial court’s jurisdiction to modify a death sentence under PC 1172.75.

Case Name: People v. Dixon (2025) 112 Cal.App.5th 236, review granted 10/22/25
Case #: S292223/B335987
Last Updated: July 15, 2026

(1) May a superior court modify a death judgment under the recall and resentencing procedure in Penal Code section 1172.75? (2) Did the Court of Appeal err in holding that the exclusivity provision of Penal Code section 1509 precludes modification of a death judgment under Penal Code section 1172.75? (3) Did the superior court have jurisdiction to resentence defendant pursuant to Penal Code section 1172.75 when his appeal was pending before this court?

Review on this issue has also been granted with briefing deferred in:

Second District

  • People v. Cain (2025) 116 Cal.App.5th 917, review granted 2/18/26 (S294810/B342911)
  • People v. Chism (B341492) [nonpub. opn.], review granted 4/15/26 (S295200)

Fourth District

  • People v. Camacho (D084857) [nonpub. opn.], review granted 3/11/26 (S294952)
  • People v. Green (E084337) [nonpub. opn.], review granted 4/29/26 (S295738)

Fifth District

  • People v. Vieira (F089727) [nonpub. opn.], review granted 6/17/26 (S296960)
  • People v. Reyes (F089378) [nonpub. opn.], review granted 7/15/26 (S296719)
  • People v. Robinson (2026) 120 Cal.App.5th 516, review granted 7/15/26 (S297048/F089332)