People v. Superior Court, 36 Cal. App. 5th 529

Two juveniles (R.Z. and K.L.), each 15 at the time of alleged offenses, were initially transferred by trial courts to adult criminal court after juvenile-court unfitness findings; both transfer orders were stayed and later vacated after enactment of S.B. 1391.
The Sacramento County District Attorney (on behalf of the People) petitioned this court for writs of mandate challenging the trial courts’ returns of the cases to juvenile court.
S.B. 1391 (2018) amended Welf. & Inst. Code § 707 to bar prosecuting 14- and 15‑year‑olds in adult criminal court (except if they remain unapprehended beyond juvenile jurisdiction), eliminating prosecutor direct‑file for that age group.
Petitioner argued S.B. 1391 unlawfully amended Proposition 57 (2016) by removing judges’ ability to transfer 14‑ and 15‑year‑olds to adult court and thus contravened the voters’ intent that a judge, not a prosecutor, decide transfers.
The court stayed juvenile proceedings pending resolution and framed the narrow legal question: whether S.B. 1391 is an unconstitutional amendment of section 707 as modified by Proposition 57.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether S.B. 1391 is an unconstitutional amendment of Proposition 57’s changes to § 707	S.B. 1391 conflicts with Prop. 57 because it prevents judges from deciding to transfer 14‑ and 15‑year‑olds to adult court; thus it contravenes the initiative’s intent	Proposition 57 allowed legislative amendments consistent with its purpose; S.B. 1391 narrows eligible youth but furthers Prop. 57’s goals (fewer youths prosecuted as adults, emphasis on rehabilitation)	Denied: S.B. 1391 is not an unconstitutional amendment; it is consistent with and furthers Prop. 57’s intent
Whether Prop. 57 specifically intended to preserve prosecution of 14‑ and 15‑year‑olds in adult court	Prop. 57’s language and materials show intent to have judges decide transfers for 14+; plaintiff reads this as preserving adult prosecution for 14‑15	The voter materials emphasize reducing youth prosecutions and vesting transfer discretion in judges (not preserving a right to prosecute 14‑15 as adults)	Held: No clear voter intent to guarantee adult prosecution for 14‑15; S.B. 1391 does not contravene Prop. 57

People v. DeLeon, 3 Cal.5th 640 (2017) (presumption that Legislature acted within authority when amending initiative statutes)
People v. Superior Court (Lara), 4 Cal.5th 299 (2018) (describing Prop. 57’s return to judge-conducted transfer hearings and effects on juvenile transfer law)
Manduley v. Superior Court, 27 Cal.4th 537 (2002) (historical framework for transfer and Proposition 21 impact)
Graham v. Florida, 560 U.S. 48 (2010) (juvenile sentencing doctrine relevant to rehabilitation and culpability of juveniles)
Miller v. Alabama, 567 U.S. 460 (2012) (juvenile-specific sentencing considerations affecting policy on juvenile prosecution)
Foundation for Taxpayer & Consumer Rights v. Garamendi, 132 Cal.App.4th 1354 (2005) (standard for evaluating whether a legislative amendment conflicts with voter‑approved initiative)