Nov. 16, 2022 – People v. Monroe (1st Dist., Div. 2, A164777)

PC 1172.75 (the SB 483 resentencing provision for prior-prison-term enhancements) provides that a court conducting a resentencing under the statute “shall apply … any … changes in law that reduce sentences or provide for judicial discretion so as to eliminate disparity of sentences and to promote uniformity of sentencing.” The Court of Appeal holds that this language requires a court conducting a resentencing under PC 1172.75 to apply SB 620 and SB 1393, including where the defendant’s original judgment of conviction became final prior to those bills’ effective dates.

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