People v. Meza CA4/1

DISCUSSION

For our purposes, it is sufficient to address the trial court’s conclusion that the jury’s true finding on the felony murder special circumstance based on mayhem establishes that Meza remains liable for murder under current law. Because this finding indicates his murder conviction is entirely unaffected by the recent statutory changes, he is ineligible for resentencing relief as a matter of law. In People v. Strong (2022) 13 Cal.5th 698 (Strong), the Supreme Court addressed whether defendants found to have committed a special circumstance felony murder (§ 190.2, subd. (a)(17)) before the decisions in People v. Banks (2015) 61 Cal.4th 788 and People v. Clark (2016) 63 Cal.4th 522 (Clark) could still state a prima facie case for relief under section 1172.6. It concluded that for trials conducted before the decisions in Banks and Clark, a felony-murder special circumstance finding does not conclusively preclude a prima facie case under section 1172.6. (Strong, at p. 710.) But the trial in this case took place after both Banks and Clark were decided. And as the court in Strong made clear, “findings made after Banks and Clark ordinarily establish a defendant’s ineligibility…