P. v. Coleman CA3
In 2006 defendant Raymond Nelson Coleman was convicted of murder and sentenced to life without parole (LWOP). He committed the crimes when he was 21. On appeal, he contends the trial court erred in denying his petition for recall and resentencing pursuant to Penal Code section 1170, subdivision (d)(2) (hereafter, section 1170(d)(2)). According to defendant, section 1170(d)(2) violates his equal protection rights because it limits relief to juveniles sentenced to LWOP, whereas certain offenders age 25 years or younger are eligible for youth parole hearings under section 3051, depending on their sentence and time served.
We requested the parties to provide supplemental briefing regarding the recent amendments to section 3051, including the amendments increasing the eligibility age from 23 years to 25 years and adding eligibility for juvenile defendants sentenced to LWOP, and the recent decision in People v. Contreras (2018) 4 Cal.5th 349 (Contreras), which held that sentences of 50
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