People v. Dawson CA3

DISCUSSION

We evaluate the specific arguments presented but need not independently review the record. (People v. Delgadillo, supra, 14 Cal.5th at pp. 231-232.) I Legal Background Senate Bill No. 1437 (2017-2018 Reg. Sess.) (Senate Bill 1437) narrowed the scope of the felony-murder rule and eliminated the natural and probable consequences doctrine as a basis for murder liability. (People v. Curiel (2023) 15 Cal.5th 433, 448- 449.) The Legislature did so “to ensure that murder liability is not imposed on a person who is not the actual killer, did not act with the intent to kill, or was not a major participant in the underlying felony who acted with reckless indifference to human life.” (Stats. 2018, ch. 1015, § 1, subd. (f).) Senate Bill 1437 also added former section 1170.95, current section 1172.6, which allows those convicted of murder, attempted murder, or manslaughter under a now- invalid theory to petition the trial court to vacate the conviction and resentence the defendant. (§ 1172.6, subd. (a); Stats. 2022, ch. 58, § 10.) If the trial court finds that a petitioning defendant has made a prima facie showing of entitlement to relief, the court must issue an order to show…