People v. Emanuel, 17 Cal.5th 867

Louis Sanchez Emanuel was convicted of first-degree murder under California’s felony-murder rule after his codefendant, Whitley, fatally shot Sonenberg during a marijuana robbery.
At the time, felony-murder liability only required intent to commit the underlying felony; later law (Senate Bill No. 1437) imposed stricter mens rea requirements—major participation and reckless indifference to human life.
After Senate Bill No. 1437 became law, Emanuel filed a petition to vacate his murder conviction, arguing he did not act with reckless indifference.
The trial court denied relief, finding he was a major participant who acted with reckless indifference, and the Court of Appeal affirmed.
The Supreme Court reviewed whether there was sufficient evidence Emanuel acted with reckless indifference to human life under the amended standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Emanuel act with reckless indifference to human life in the murder?	Emanuel failed to restrain Whitley, could have prevented violence	He did not know Whitley was armed or would use lethal force	No; insufficient evidence of reckless indifference
Should Emanuel’s murder conviction stand under Senate Bill No. 1437?	Participating in the robbery with opportunity to intervene suffices	New law requires proof of reckless indifference not present here	No; conviction must be vacated, case remanded

People v. Banks, 61 Cal.4th 788 (Cal. 2015) (established factors for assessing major participant and reckless indifference in felony murder)
People v. Clark, 63 Cal.4th 522 (Cal. 2016) (elaborated on factors for reckless indifference in felony murder)
In re Scoggins, 9 Cal.5th 667 (Cal. 2020) (affirmed need for individualized, fact-intensive analysis for reckless indifference)
People v. Strong, 13 Cal.5th 698 (Cal. 2022) (confirmed new felony-murder limits and application of Banks and Clark factors)