In re Stevenson, 152 Cal. Rptr. 3d 457

James L. Stevenson, an indeterminate life prisoner for kidnapping to commit robbery, petitioned for habeas corpus after the Board denied parole in June 2010.
Stevenson alleged lack of some evidence of current dangerousness and lack of a rational nexus between unsuitability factors and current danger.
Petitioner submitted two risk assessments (Black 2009, Lehrer 2010) and related materials; respondent submitted additional documents including prior RVRs and a summary of risk literature.
The superior court granted habeas relief, faulted the Board’s analytical framework, and ordered a new parole hearing within 100 days.
The Board appealed, and the appellate court reversed, holding the petition should have been denied and the original decision sustained.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether some evidence supports denial of parole	Stevenson argues no current danger supported by evidence.	Board argues there is some evidence of current risk, including risk assessments and offense factors.	Some evidence supports denial
Whether the court exceeded authority by requesting new expert declarations	The petition raised only two grounds; new expert material should not have been admitted.	No new claims; court improperly framed new questions and invited extra evidence.	Court exceeded authority; reversal required
Whether the court relied on the Board's weighing language to vacate the decision	Weighing language shows improper independent weighting of factors.	Weighing is permissible with due consideration; not inherently unlawful.	Weighing language does not invalidate the decision
Whether the panel's discussion of the commitment offense and risk assessments complied with the some-evidence standard	Risk assessments based on static factors or misinterpretation undermine nexus to current dangerousness.	Panel's reasoning, including insight and dynamic factors, provides a rational nexus and satisfies some evidence.	There is a rational nexus and some evidence supports denial

In re Rosenkrantz, 29 Cal.4th 616 (Cal. 2003) (some evidence standard for parole review; deferential scrutiny)
In re Lawrence, 44 Cal.4th 1181 (Cal. 2008) (parole suitability factors; nexus between factors and current dangerousness)
Shaputis II, 53 Cal.4th 192 (Cal. 2012) (reaffirms some evidence standard and evaluative framework for parole decisions)
In re Duvall, 9 Cal.4th 464 (Cal. 1995) (habeas corpus pleading requirements and evidentiary procedures)
In re Sturm, 11 Cal.3d 258 (Cal. 1974) (due process requires a statement of reasons for parole denial)