People v. Schaefer CA2/8

BACKGROUND

The facts underlying the murder conviction are not complicated. Appellant and Monica Reynoso got together at Reynoso’s apartment to manufacture methamphetamine. An explosion occurred and both were serious burned. Reynoso died one month later from her injuries. At trial, the prosecutor proceeded, and the jury was instructed, on a theory of felony murder only. The jury convicted appellant, who was sentenced to 15 years to life on the second degree murder conviction. In 2019, appellant filed a petition pursuant to section 1170.95. He alleged he was entitled to relief because he was convicted under the felony murder doctrine, which Senate Bill No. 1437 (2017–2018 Reg. Sess.) (Senate Bill 1437) had abrogated with certain exceptions not raised by the parties here.

Further undesignated statutory references are to the Penal Code.

2 The trial court appointed counsel for appellant and found he had made a prima facie case of eligibility for relief. On August 27, 2020, the trial court held an evidentiary hearing where the People introduced the trial record into evidence and appellant testified on his own behalf. After entertaining argument, the trial court concluded…