People v. Sandoval CA2/4

DISCUSSION

The Legislature eliminated “natural and probable consequences liability for murder as it applies to aiding and abetting.” (People v. Lewis (2021) 11 Cal.5th 952, 957 (Lewis).) In turn, the Legislature created a procedural mechanism for defendants who could not be convicted of murder under the amended laws to seek retroactive relief. (§ 1172.6, subd. (a)(1)-(3); Lewis, supra, at p. 957.) The Legislature then expanded the class of defendants entitled to relief to those convicted of manslaughter under the natural and probable consequences doctrine. (§ 1172.6, subd. (a)(1); see People v. Delgadillo (2022) 14 Cal.5th 216, 223, fn. 3.) The sole issue on appeal is whether the trial court engaged in improper factfinding by relying on the preliminary hearing transcript.2 While this

1 All further statutory references are to the Penal Code unless otherwise stated. 2 We grant Sandoval’s motion to augment the record to include the preliminary hearing transcript. 2 appeal was pending, our Supreme Court decided People v. Patton (2025) 17 Cal.5th 549, 600 (Patton), which held “that a petitioner who offers only conclusory allegations of entitlement to relief under section…