The People, Plaintiff and Respondent v. Patrick Lee Conley, Defendant and Appellant — Werdegar, J., Concurring

Summary

Justice Werdegar concurred in the court's conclusion that a defendant serving a third-strike life term when the Reform Act took effect may seek relief only through the statutory sentence-recall procedure, even if the underlying judgment was not yet final. She reasoned that the recall provision functions as a saving clause and clearly establishes prospective application, while preserving the established presumption favoring retroactive application of statutes reducing punishment. The concurrence explains that the court's earlier treatment of that presumption did not replace it with a general inquiry into legislative intent. Justices Liu and Cuéllar joined the concurrence.