In a case in which appellant was convicted of three first degree murders, conspiracy to commit murder, and assault with a deadly weapon, the Court of Appeal reversed the order summarily denying appellant’s Penal Code section 1170.95 petition without issuing an order to show cause and holding an evidentiary hearing, since the Court could not exclude the possibility that one or more of the murder convictions was based on the now-forbidden theory of natural and probable consequences.
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