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A two decades old murder in San Bernardino County just set precedent for interpreting one of California’s biggest criminal reforms in the past five years.

Senate Bill 1437, passed in 2018 and now codified as Penal Code Section 1172.6, restricted a rule that allowed people to be convicted for murder even if they did not directly kill the victim. For example, a person who committed a home invasion, during which a co-perpetrator fatally shot the homeowner, could be convicted of murder. 

The rule was inherited from English Common Law, but had been walked back in most countries that had adopted it, according to a 2018 California Senate report. England and Wales removed

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