Apr. 11, 2023 – In re T.A. (4th Dist., Div. 2, E079346)

The Court of Appeal holds that AB 2361, which amended WIC 707‘s procedures for transferring a minor from juvenile to adult court, applies retroactively. However, remand for a new transfer hearing was not necessary because the application of a lesser burden of proof than is now required was harmless error under the Watson standard. The court rejects appellant’s argument that the “clear indication standard” articulated in People v. Gutierrez applies.