People v. Amador CA2/2, B305288A

In 2003 Carlos Amador pleaded guilty to four counts of second-degree murder and received four concurrent 15-years-to-life terms for an arson/homicide that killed four members of a family.
Evidence (preliminary hearing transcript and codefendant trial testimony) shows Amador participated in the home invasion, helped bind victims, took property, poured flammable liquid at the victims’ home, and left before the fire fully consumed the house.
Amador filed a section 1170.95 petition (April 22, 2019) asserting that post-2019 amendments to sections 188 and 189 could make him ineligible for murder conviction under current law.
The People opposed; the trial court denied the petition (Jan. 17, 2020), finding Amador was a major participant who acted with conscious/reckless disregard for human life and therefore not entitled to relief.
The Court of Appeal initially affirmed, but the California Supreme Court granted review and transferred the case back for reconsideration in light of People v. Lewis (2021).
On remand the People conceded the record does not conclusively refute Amador’s eligibility; the Court of Appeal reversed the trial court and remanded with directions to issue an order to show cause and hold an evidentiary hearing under section 1170.95(d).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Amador made a prima facie showing under §1170.95 requiring an order to show cause	People argued the record supports denial because Amador was a major participant who acted with conscious disregard; thus no relief	Amador argued his petition facially stated the elements for relief and the record does not conclusively disprove eligibility	Court held Amador satisfied prima facie requirements; trial court erred by denying without issuing an order to show cause
Whether the trial court could make ultimate factual findings (major participant/reckless indifference) at prima facie stage from the record	People contended the record demonstrates those facts as a matter of law, justifying denial	Amador contended credibility/factual weighing is required at an evidentiary hearing and cannot be resolved at prima facie stage	Court held trial court impermissibly engaged in factfinding/weighing at prima facie stage; such determinations require an evidentiary hearing where People must prove ineligibility beyond a reasonable doubt

People v. Lewis, 11 Cal.5th 952 (2021) (clarifies scope of prima facie inquiry under §1170.95 and limits on resolving disputed factual issues without a hearing)
People v. Drayton, 47 Cal.App.5th 965 (2020) (explains that trial court may rely only on readily ascertainable record facts at prima facie stage, not weighing credibility)
People v. Sanchez, 48 Cal.App.5th 914 (2020) (confirms §1170.95 applies to convictions obtained by plea as well as by trial)
Martinez v. Brownco Constr. Co., 56 Cal.4th 1014 (2013) (supports de novo review for application of law to undisputed facts)
A.S. v. Miller, 34 Cal.App.5th 284 (2019) (addresses standard of review for statutory interpretation)