P. v. Brizuela-Navas CA1/5
On November 8, 2016, the electorate of California passed Proposition 57, the “Public Safety and Rehabilitation Act of 2016.” Among other things, Proposition 57 required that prosecutions against defendants who committed their crimes as juveniles be commenced in juvenile court and eliminated provisions that had allowed the district attorney to bring certain criminal charges directly against juvenile defendants in adult court. (Compare Welf. & Inst. Code, §§ 602, 707 with former §§ 602, 707.) Our Supreme Court has held that juvenile defendants whose convictions were not yet final at the time of the passage of Proposition 57 are entitled to retroactive application of the new law. (People v. Superior Court (Lara) (2018) 4 Cal.5th 299, 303 (Lara).) We conclude appellant Luis Brizuela-Nava’s conviction was final as of the date Proposition 57 was effective and he is not entitled to relief under that provision. We reject his remaining claims and affirm.
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