P. v. Cramer CA2/4
Following a suitability hearing under the Three Strikes Reform Act of 2012, enacted by the voters as Proposition 36 (Pen. Code, § 1170.126), the trial court determined that the defendant, Larry Lee Cramer, posed an unreasonable risk of danger to public safety and denied his petition for resentencing. On appeal, defendant contends the trial court erred in failing to apply the narrower definition of “unreasonable risk of danger to public safety” found in the more recently enacted Proposition 47, the Safe Neighborhoods and Schools Act of 2014 (§ 1170.18). He also argues that, even if the Proposition 47 definition does not apply, the trial court’s unreasonable risk determination was an abuse of discretion. We disagree and affirm the order denying the petition.
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