California, United States of America
The following excerpt is from People v. McShane, 248 Cal.Rptr.3d 322, 36 Cal.App.5th 245 (Cal. App. 2019):
"The purpose of the ex post facto doctrine is to ensure fair notice of the conduct that constitutes a crime and of the punishment that may be imposed for a crime. [Citation.]" ( In re Vicks (2013) 56 Cal.4th 274, 287, 153 Cal.Rptr.3d 471, 295 P.3d 863, fn. omitted.) Hence, " the operative event for retroactivity purposes, and the necessary reference point for any ex post facto analysis, is criminal conduct committed before the disputed law took effect. [Citation.]" ( People v. Trujeque (2015) 61 Cal.4th 227, 256, 188 Cal.Rptr.3d 1, 349 P.3d 103, italics added.)
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