People v. Price CA4/1

Good Law
Court of Appeal of CaliforniaJanuary 21, 2026D084723California2,209 words

Opinion

Opinion

DISCUSSION

I. Section 1172.

Effective January 1, 2019, the Legislature “ ‘eliminated natural and probable consequences liability for murder as it applies to aiding and abetting, and limited the scope of the felony-murder rule.’ [Citation.] [It] also added section 1170.95, now section 1172.6, to provide ‘a procedure for convicted murderers who could not be convicted under the law as amended to retroactively seek relief.’ ” (People v. Antonelli (2025) 17 Cal.5th 719, 723-

3 724.) Thereafter, Senate Bill No. 775 expanded the path to resentencing under the law “to allow relief for those with ‘attempted murder’ convictions based on ‘the natural and probable consequences doctrine.’ ” (People v. Patton (2025) 17 Cal.5th 549, 558.) Section 1172.6 “provides that ‘a person convicted of . . . attempted murder under the natural and probable consequences doctrine . . . may file a petition with the court that sentenced the petitioner to have the petitioner’s . . . conviction vacated and to be resentenced on any remaining counts when’ three conditions apply. [Citation.] As relevant here . . . those enumerated conditions are: First, the charging document allowed the prosecution to ‘proceed…

Sign in to read the full opinion

Create a free account to read the complete opinion text, citation history, and good-law status for this case.