The California Supreme Court ruled Oct. 9 in *People v. Superior Court (Guevara)* on the application of the Three Strikes Reform Act of 2012, addressing a critical issue affecting thousands of inmates serving life sentences under California's original Three Strikes law.
Justice Evans authored the majority opinion, joined by Justices Liu, Kruger, Groban, and Jenkins. Justice Corrigan filed a dissenting opinion, joined by Chief Justice Guerrero, creating a 5-2 split on the court.
The case centers on Edgardo Ortiz Guevara, who received a sentence of 28 years to life in 2009 following his third strike conviction under California's original Three Strikes law. At the time, the law required indeterminate life sentences for any third felony conviction, regardless of the severity of the offense.
In 2012, California voters approved the Three Strikes Reform Act, also known as Proposition 36, which fundamentally changed the state's sentencing structure. The Reform Act limited indeterminate life sentences to cases where the third strike offense was serious or violent. Under the new framework, defendants convicted of nonserious, nonviolent third strikes receive a sentence of double the term of the current felony rather than life imprisonment.
The Reform Act included a retroactive provision allowing defendants "presently serving an indeterminate term of imprisonment" for nonserious, nonviolent third strikes to petition for resentencing. This provision, codified in Penal Code Section 1170.126, created a pathway for inmates like Guevara to seek relief from their life sentences.
Guevara filed a petition for resentencing in 2013 under Section 1170.126, seeking to reduce his 28-year-to-life sentence. However, the trial court denied his petition after determining that his release would pose an unreasonable risk of danger to public safety. The Reform Act specifically authorizes courts to deny petitions from defendants who pose such a risk to public safety.
The case reached the California Supreme Court through a complex procedural path involving the Santa Barbara County Superior Court and the Second Appellate District, Division Six. The high court's review focused on the proper interpretation and application of the Reform Act's resentencing provisions.
The majority opinion by Justice Evans provides guidance on how courts should evaluate petitions for resentencing under the Three Strikes Reform Act. While the complete details of the court's reasoning are not fully available, the decision appears to address fundamental questions about the scope of relief available under Proposition 36.
The Reform Act's public safety exception has been a source of ongoing litigation since its enactment. Courts must balance the legislature's intent to reduce sentences for nonviolent offenders against concerns about protecting public safety. The determination of what constitutes an "unreasonable risk of danger to public safety" requires careful consideration of various factors, including an inmate's criminal history, institutional behavior, and rehabilitation efforts.
Justice Corrigan's dissent, joined by Chief Justice Guerrero, suggests the minority had a different interpretation of how the Reform Act should be applied. Dissenting opinions often reflect concerns about the majority's reasoning or the potential consequences of the ruling.
The case also references Senate Bill legislation enacted by the Legislature in 2021, indicating that California lawmakers have continued to refine the state's sentencing laws. This ongoing legislative activity demonstrates the evolving nature of California's approach to criminal justice reform.
The decision comes at a time when California continues to grapple with prison overcrowding and criminal justice reform. The Three Strikes law, originally enacted in 1994, was designed as a deterrent to repeat offenders but has faced criticism for imposing disproportionately harsh sentences on nonviolent offenders.
The Reform Act represented a significant shift in California's sentencing philosophy, acknowledging that not all third strike offenses warrant life imprisonment. Since its enactment, thousands of inmates have sought relief under its provisions, making the Supreme Court's guidance on its application particularly important.
The ruling in *Guevara* will likely influence how trial courts across California evaluate future resentencing petitions. Defense attorneys representing inmates serving life sentences under the original Three Strikes law will closely examine the decision for guidance on presenting their clients' cases.
For prosecutors, the decision provides clarity on the standards for opposing resentencing petitions based on public safety concerns. District attorneys' offices throughout the state have taken varying approaches to these petitions, with some supporting relief for certain categories of offenders while opposing others.
The case underscores the ongoing tension between public safety concerns and efforts to reform California's sentencing laws. As the state continues to address issues of mass incarceration and prison reform, decisions like *Guevara* shape the legal landscape for both current inmates and future defendants.
The Supreme Court's ruling will be closely watched by criminal justice advocates, defense attorneys, prosecutors, and inmates throughout California's prison system who may be eligible for similar relief under the Three Strikes Reform Act.