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P. v. Harrell CA4/3
This is an appeal from the denial of defendant’s petition for resentencing under Penal Code section 1170.95. In his petition, defendant declared that he was convicted of murder under a theory of natural and probable consequences, which is no longer a valid ground to support a murder conviction. The trial court denied the petition at the prima facie stage without issuing an OSC. The court reasoned that defendant was also convicted of burglary, and that charge required the jury to find defendant intended to commit murder.

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