On August 8, 2022, the California Supreme Court reversed the decision of the court of appeal affirming the judgment of the trial court denying Appellant's petition for resentencing under Senate Bill No. 1437, holding that certain special circumstance findings did not preclude him from making out a prima facie case for resentencing.
In 2014, a jury convicted Strong of felony murder and found "true" the felony-murder special-circumstance allegation that Strong was a "major participant" who acted with "reckless indifference to human life" under California Penal Code section 190.2 subdivision (d). Afterwards, the Supreme Court decided People v. Banks, 61 Cal. 4th 788 (2015) and People v. Clark, 63 Cal.4th 522 (2016), which gave guidance on the meaning of the phrases "major participant" and "with reckless indifference to human life." In 2018, the Legislature adopted Senate Bill 1437. Strong then, under SB 1437, petitioned for resentencing. The trial court denied the petition. The California Supreme Court reversed. The California Supreme Court held (1) findings issued by a jury before Banks and Clark do not preclude a defendant from making out a prima facie case for relief under Senate Bill 1437; and (2) because Strong's case was tried before both Banks and Clark, the special circumstance findings did not preclude him from proving a prima facie case for resentencing under Penal Code section 1172.6 (SB 1437)