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P. v. Britten CA1/4
In July 2013, Vernon Britten filed a petition to recall his sentence under Penal
Code section 1170.126, a provision of the Three Strikes Reform Act of 2012, which was
enacted pursuant to Proposition 36 (the Act or Proposition 36).1
In October 2014, the
trial court denied Britten’s petition on the ground that releasing him from prison would
pose an unreasonable risk of danger to public safety.

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