People v. Curiel

Summary

The court held that the jury's intent-to-kill finding was entitled to issue-preclusive effect in the defendant's resentencing proceeding, but that finding, alone or combined with the other findings necessarily reflected in the verdicts and instructions, did not conclusively establish murder liability under current law. Because the record did not refute the defendant's prima facie eligibility under section 1172.6, the trial court erred by denying the petition without issuing an order to show cause and proceeding to an evidentiary hearing. The court affirmed the Court of Appeal's judgment reversing the trial court.