People v. Lynch

This case addresses whether the 2011 realignment legislation addressing public safety (hereafter Realignment Act; Stats. 2011, ch. 15) must be applied retroactively to all defendants whose convictions are not yet final. We find that a defendant’s right to equal protection of the law does not prevent the Legislature’s limiting the act’s application to felons sentenced on or after its operational date of October 1, 2011.

*357 BACKGROUND

We dispense with a recitation of the facts of the crimes as they are unnecessary to resolve this appeal.

Defendant Deandre Deshawn Lynch pleaded no contest to possession of methamphetamine with a prior narcotics conviction (Health & Saf. Code, §§ 11378, 11370.2, subd. (c)) in case No. 101550 and failure to appear (Pen. Code, § 1320, subd. (b)) in case No. 101776. 1 On June 7, 2011, he was sentenced to a stipulated term of four years four months in state prison.

DISCUSSION

I

The Realignment Act significantly changes felony punishment. Under prior law, felonies were offenses punished by death or imprisonment in state prison. (§ 17, former subd. (a).) The Realignment Act changes the definition of a felony to an offense punishable by…