May 4, 2026
Supreme Court of California
The Rule of People v. Morris is that under Penal Code section 189, subdivision (e)(2), a nonkiller defendant must aid or abet the actual killer in the lethal act itself, not just the underlying felony, under the amended felony-murder rule where the defendant acted with intent to kill.
January 28, 2026
Court of Appeal, Second Appellate District, Division One
The Rule of **People v. Diaz** is that trial courts are not required to expressly state they have considered a defendant's youth when determining whether the defendant acted with express malice/intent to kill in section 1172.6 proceedings, under circumstances where the court is aware of the defendant's age and counsel argues youth as a mitigating factor but the court finds the defendant personally intended the victims' deaths.
5/21/26
Court of Appeal, Fourth Appellate District, Division Two
The Rule of People v. Tyus is that at a Penal Code section 1172.6 evidentiary hearing, the prosecution must prove beyond a reasonable doubt that a petitioner is guilty of murder under current law—it is not the petitioner's burden to prove an alternate murder theory existed, under circumstances where the petitioner has established a prima facie case for relief and was not the actual killer.