P. v. Cruz CA6
Howard (2020) 50 Cal.App.5th 727 (Howard)—a pre- Arellano case affirming the reimposition of an arming enhancement after a murder conviction was vacated under section 1172.6 and redesignated as the underlying burglary offense. As we will explain, although Arellano did not directly address whether Howard was correctly decided, we find aspects of Howard difficult to square with the Supreme Court’s reasoning in Arellano and conclude that r
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