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In re Morrison CA4/2
In 2005, a jury convicted petitioner Sinque Morrison of, among other things, first degree murder and attempted murder for his involvement in the shooting death of 11-year-old Mynisha Crenshaw. In 2014, the California Supreme Court held that the natural and probable consequences doctrine is not a valid theory of liability for first degree murder. (People v. Chiu (2014) 59 Cal.4th 155 (Chiu).) Morrison subsequently filed a petition for writ of habeas corpus in which he alleged the trial court impermissibly instructed the jury on the natural and probable consequences doctrine in violation of Chiu.
After we summarily denied the petition, the California Supreme Court vacated our opinion and directed us to order the People to show cause why Morrison’s requested relief should not be granted. After receiving further briefing from the parties, we again denied Morrison’s writ petition for habeas corpus relief.

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