P.

BACKGROUND

On four separate occasions in 1997 and 1998, defendant robbed four different banks. In February 1998, defendant pled guilty to four counts of second degree robbery, and admitted two prior convictions and two prior prison terms. The trial court sentenced defendant to a total term of 110 years to life, pursuant to Penal Code sections 667, subdivisions (d) and (e)(2), and 1170.12, subdivisions (b) and (c)(2). In January 2013, defendant filed a petition for recall and resentencing, pursuant to Penal Code section 1170.126, subdivision (b). The trial court denied the petition, and defendant appealed.

ANALYSIS OF POTENTIAL ISSUES

Appointed counsel suggests we consider a single issue: whether defendant was entitled to a reduction in his sentence, pursuant to Penal Code section 1170.126. On November 6, 2012, the electorate passed Proposition 36, the Three Strikes Reform Act of 2012. “Under the three strikes law as it existed before the passage of the Reform Act, a

2 defendant with two or more strike priors who is convicted of any new felony would receive a sentence of 25 years to life. ([Pen. Code, f]ormer § 667[, subd. ](e)(2)(A).) As amended, [Penal Code] section 667…