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Evidentiary Hearing Ordered in 1437 Case with No FM/NPC

People v. Maldonado Docket: A161817A (First Appellate District), Opinion Date: January 30, 2023. In 2001, a body was found with multiple stab wounds. Maldonado reported witnessing the killing and seeing a man with blood on his chest who may have been the killer. Police found a sweatshirt and knife buried in the yard of Maldonado’s former residence, and found a photograph of Morales with the victim’s body in Maldonado’s residence at the time of his arrest. Maldonado, charged with first-degree murder with an allegation that the murder was committed by means of lying in wait, testified that Morales took him to the body after the killing; Maldonado helped Morales bury the evidence. The jury was instructed on willful, deliberate, and premeditated murder; lying in wait; and direct aiding and abetting. It was not instructed on felony murder or the natural and probable consequences doctrine. The jury convicted Maldonado of first-degree murder. In 2019, Senate Bill 1437 eliminated natural and probable consequences liability for murder as it applies to aiding and abetting, and limited the scope of the felony-murder rule, allowing retroactive relief. The trial court summarily denied Maldonado's petition for resentencing, finding that Maldonado’s conviction was not obtained under a felony murder or natural and probable consequences theory. The court of appeal remanded, An evidentiary hearing is required; the court may find that Maldonado was the actual killer or that he was an aider and abettor who facilitated the killing with personal disregard for human life, in which case his petition will be denied. Otherwise, he will be entitled to relief.

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