AB 103 Rule Constitutional, Remanded

California v. Steward Court: California Courts of Appeal, Docket: C091715 (Third Appellate District), Opinion Date: April 30, 2021. Defendant Troy Steward was charged with battery on a correctional officer, and he was committed to Atascadero State Hospital after being found not guilty by reason of insanity. Following the passage of Assembly Bill No. 103 (2017-2018 Reg. Sess.) (Assem. Bill 103), defendant filed a petition for a reduction of his commitment under newly enacted Penal Code section 1170.127, a statute which paralleled Three Strikes relief for those found guilty of a crime. The superior court denied defendant’s petition, concluding that Assembly Bill 103 was an unconstitutional amendment of Proposition 36, the Three Strikes Reform Act of 2012. The Court of Appeal found Assembly Bill 103 did "not amend Proposition 36 to prohibit what Proposition 36 authorized or authorize what it prohibited: [w]hile Proposition 36 addresses the length of prison sentences for criminal defendants, Assembly Bill 103 addresses the length of commitment terms for NGI committees." The trial court was reversed and the case remanded for further proceedings.