People v. Medrano CA2/4, B335521

Jason Jeremiah Medrano was originally charged with murder in 2015 but pleaded no contest to voluntary manslaughter, admitting personal use of a firearm and committing the crime for the benefit of a street gang.
Medrano was sentenced to 23 years in state prison as part of his plea agreement.
In 2018, legislative changes to California’s homicide laws (SB 1437, SB 775) allowed certain individuals convicted of murder or manslaughter under the "natural and probable consequences" doctrine to petition for resentencing.
Medrano filed a petition under Penal Code section 1172.6, seeking resentencing based on the updated law, arguing he could not now be convicted of murder under the amended statutes.
The trial court denied the petition, relying on the preliminary hearing transcript to determine Medrano was the actual killer, thus ineligible for relief without an evidentiary hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether court may use preliminary hearing transcript to deny section 1172.6 relief at prima facie stage	Medrano did not meet eligibility for resentencing; the transcript shows he's the actual killer	The court unlawfully relied on preliminary transcript and made impermissible factual findings	The court may use the transcript in screening for eligibility per People v. Patton
Opportunity to amend petition	Not specifically addressed	Sought opportunity to amend if ruling affirmed	Remanded to allow Medrano to file an amended petition

People v. Patton, 17 Cal.5th 549 (Cal. 2025) (trial court may use preliminary hearing transcript to refute conclusory allegations at prima facie stage in resentencing petitions)
People v. Lewis, 11 Cal.5th 952 (Cal. 2021) (procedure for prima facie determination under section 1172.6)
People v. Hin, 17 Cal.5th 401 (Cal. 2025) (clarified resentencing eligibility for those convicted of voluntary manslaughter by plea)
People v. Garcia, 97 Cal.App.4th 847 (Cal. Ct. App. 2002) (summary disposition context in memorandum opinions)