In 2023, Nolen asked the trial court to resentence him pursuant to the newly enacted Penal Code section 1172.75 and to dismiss his prior strike conviction and all of the enhancements. The People argued that Nolen was not eligible for resentencing under section 1172.75 because the sentencing court had stayed the prior prison term enhancement. The court agreed with the People, citing People v. Rhodius (2023) 97 Cal.App.5th 38, reversed in People v. Rhodius (2025) 17 Cal.5th 1050, and declined to resentence Nolen. Six months after the trial court issued its order, the California Supreme Court reversed the decision on which the trial court had relied. Based on this new authority, the Court of Appeal reversed the denial of resentencing and remanded for further proceedings.