Appellant’s first petition under Senate Bill no. 1437 was denied based on facts recited in the opinion on direct appeal. The denial was affirmed on appeal. Senate Bill No. 775 (2019-2020 Reg. Sess.) subsequently changed the law to clarify that a trial court may not rely on factual summaries in an appellate opinion at the prima facie stage. Appellant filed a second petition, which the trial court denied as successive. The Court of Appeal agreed with appellant that the second petition was not procedurally barred as a successive petition, due to the changes in the law made by Senate Bill No. 775. (People v. Farfan (2021) 71 Cal.App.5th 942, 951.) The error was not harmless. The Court of Appeal remanded the matter to the trial court with directions to issue an order to show cause and conduct an evidentiary hearing.