P. v. Guadarrama CA4/3
In 2011, a jury found defendant Prospero Ramirez Guadarrama guilty of two counts of murder and one count of attempted murder. The jury also found true a gang special circumstance allegation, and a multiple murder special circumstance allegation. The trial court imposed a life sentence.
In 2020, the trial court denied defendant’s Penal Code section 1170.95 petition, finding that the jury’s true findings on the two special circumstance allegations rendered him ineligible for relief as a matter of law. We disagree.
The trial court instructed the jury on the natural and probable consequences doctrine, which is no longer a valid theory of murder liability. While the special circumstance allegations required the jurors to find defendant acted with the intent to kill (the mens rea), the special circumstance allegations did not require the jurors to find defendant directly aided and abetted the target crime of murder (the actus reus).
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