McClure

I. INTRODUCTION

In 2017, after initially having been charged with willful, deliberate, and premeditated murder (Pen. Code, § 187, subd. (a))1, defendant Julie Ann McClure pleaded no contest to voluntary manslaughter (§ 192, subd. (a)) and 11 other crimes pursuant to a plea agreement. The superior court imposed an agreed-upon determinate sentence of 25 years. In 2020, defendant filed a petition for resentencing pursuant to section 1170.95, which was enacted through the passage of Senate Bill No. 1437 (2017-2018 Reg. Sess.) (Senate Bill 1437). (Stats. 2018, ch. 1015, § 4.) Senate Bill 1437 “amend[ed] the felony murder rule and the natural and probable consequences doctrine . . . 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 of the underlying felony who acted with reckless indifference to human life.” (Stats. 2018, ch. 1015, § 1, subd. (f).) It added

1 All further statutory references are to the Penal Code unless otherwise specified. section 1170.95 to allow individuals “convicted of felony murder or murder under a natural and probable consequences theory” to petition…