Griffin

BACKGROUND

In 2014, a jury found defendant guilty of various offenses, including two counts of

first-degree murder (§ 187, subd. (a)) with gang and multiple-murder special

circumstances (§ 190.2, subds. (a)(3), (a)(22)), and with enhancements for causing death

by personally and intentionally discharging a firearm (§ 12022.53(d)). The trial court

sentenced defendant to four consecutive life terms (two without possibility of parole and

two with 25-year minimum parole periods) plus seven years. In his appeal from the

judgment, defendant raised several issues, including a claim that the evidence was

insufficient to support the jury’s finding that he was the shooter. We affirmed. (People

v. Griffin (July 19, 2016, E062831) [nonpub. opn.].)

1 Section 1170.95 was renumbered as section 1172.6 without change in the text, effective June 30, 2022 (Stats. 2022, ch. 58, § 10). For the sake of simplicity, we refer to the section by its new numbering. All further statutory references are to the Penal Code.

2 In 2018, the Legislature enacted Senate Bill 1437, which amended sections 188

and 189 to eliminate criminal liability for murder under the natural and probable

consequences…