In 2019, appellant filed a petition for resentencing pursuant to Penal Code section 1170.95 (now 1172.6), which was summarily denied because the statute did not provide relief for those convicted of voluntary manslaughter. On appeal, appellant argued Senate Bill No. 775 (2021-2022 Reg. Sess.), which amended section 1172.6 to expressly permit resentencing of certain individuals convicted of manslaughter, applied, requiring reversal. The Court of Appeal agreed, reversed the denial of appellant’s 1172.6 petition, and remanded for further proceedings.