Oct. 12, 2022 – Review Grant – People v. Burgos (S274743, H045212)

After initially granting review and deferring further action pending People v. Tran (2022) 13 Cal.5th 1169, the Supreme Court orders briefing on the following issue: “Does the provision of Penal Code section 1109 governing the bifurcation at trial of gang enhancements from the substantive offense or offenses apply retroactively to cases that are not yet final?”