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P. v. Allen CA4/1
In 2005, Earl Allen pleaded guilty to one count of second degree murder and was sentenced to 15 years to life in prison. The charge arose after he and three others engaged in a series of shootings that left one man dead. As the factual basis for his plea, Allen admitted he “was present, had knowledge of and aided and abetted the taking of the life of [the victim.]”
In 2019, Allen filed a petition for resentencing under Senate Bill No. 1437 (2017–2018 Reg. Sess.) (Senate Bill 1437), which amended the “felony murder rule and the natural and probable consequences doctrine, as it relates to murder, to ensure that murder liability is not imposed on a person who is not the actual killer, did not act with the intent to kill, or was not a major participant in the underlying felony who acted with reckless indifference to human life.” (Stats. 2018, ch. 1015, § 1 subd. (f).)

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