California, United States of America
The following excerpt is from People v. Madsen, C089665 (Cal. App. 2020):
On May 17, 2019, the trial court issued an order with an accompanying statement of decision summarily denying defendant's petition for resentencing with no hearing. In the statement of decision, the trial court said defendant was convicted of second degree murder on a malice theory, not felony murder or the natural and probable consequences doctrine, and that there was sufficient evidence to support the malice theory. For facts, the trial court relied on this court's opinion in defendant's direct appeal. (People v. Madsen (Jan. 15, 1995, C008672) [nonpub. opn.].) The trial court also denied the requests from defendant and the Public Defender regarding appointment of counsel.
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