P. v. Serrano CA4/3
Appellant Zeus Murillo Serrano appeals the denial of his petition for resentencing pursuant to Penal Code section 1170.95, which was enacted as part of a measure that restricted liability for the crime of murder. (See Sen. Bill No. 1437 (2017-2018 Reg. Sess.).) Under that section, a murderer may apply for resentencing if he was convicted under vicarious liability principles, but he is not entitled to relief if the record of conviction shows he acted with actual malice, i.e., the intent to kill. (See People v. Lewis (2021) 11 Cal.5th 952; People v. Gentile (2020) 10 Cal.5th 830.)
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