prospective-only presumption (California) · Go Syfert
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prospective-only presumption in California

18 California opinions name it 3 courts 2002–2017 0 in the last five years

The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (6)

CaseFollowedCited
People v. Browngreen
cal · 2012 · cited in 17 California opinions naming this issue, 2015–2017
2 sentences

2017Section 3 specifies that no part of the Penal Code “is retroactive, unless expressly so declared.” This language “erects a strong presumption of prospective operation, codifying the principle that, ‘in the absence of an express retroactivity provision, a statute will not be applied retroactively unless it is very clear from extrinsic sources that the Legislature [or electorate] . . . must have intended a retroactive application.’ [Citations.] Accordingly, ‘ “a statute that is ambiguous with respect to retroactive application is construed ... to be unambiguously prospective.” ’ [Citation.]” (Pe

2017Section 3 specifies that no part of the Penal Code “is retroactive, unless expressly so declared.” This language “erects a strong presumption of prospective operation, codifying the principle that, ‘in the absence of an express retroactivity provision, a statute will not be applied retroactively unless it is very clear from extrinsic sources that the Legislature [or electorate] . . . must have intended a retroactive application.’ [Citations.] Accordingly, ‘ “a statute that is ambiguous with respect to retroactive application is construed ... to be unambiguously prospective.” ’ [Citation.]” (Pe

617
People v. Nasalgagreen
cal · 1996 · cited in 2 California opinions naming this issue, 2016–2017
2 sentences

2016Section 3 specifies that no part of the Penal Code "is retroactive, unless expressly so declared." 12 This language "erects a strong presumption of prospective operation, codifying the principle that, 'in the absence of an express retroactivity provision, a statute will not be applied retroactively unless it is very clear from extrinsic sources that the Legislature [or electorate] ... must have intended a retroactive application.' [Citations.] Accordingly, ' "a statute that is ambiguous with respect to retroactive application is construed ... to be unambiguously prospective." ' [Citation.]" (

2016Section 3 specifies that no part of the Penal Code "is retroactive, unless expressly so declared." 12 This language "erects a strong presumption of prospective operation, codifying the principle that, 'in the absence of an express retroactivity provision, a statute will not be applied retroactively unless it is very clear from extrinsic sources that the Legislature [or electorate] ... must have intended a retroactive application.' [Citations.] Accordingly, ' "a statute that is ambiguous with respect to retroactive application is construed ... to be unambiguously prospective." ' [Citation.]" (

22
People v. Shabazzgreen
calctapp · 2015 · cited in 2 California opinions naming this issue, 2016–2017
2 sentences

2016Section 3 specifies that no part of the Penal Code "is retroactive, unless expressly so declared." 12 This language "erects a strong presumption of prospective operation, codifying the principle that, 'in the absence of an express retroactivity provision, a statute will not be applied retroactively unless it is very clear from extrinsic sources that the Legislature [or electorate] ... must have intended a retroactive application.' [Citations.] Accordingly, ' "a statute that is ambiguous with respect to retroactive application is construed ... to be unambiguously prospective." ' [Citation.]" (

2016Section 3 specifies that no part of the Penal Code "is retroactive, unless expressly so declared." 12 This language "erects a strong presumption of prospective operation, codifying the principle that, 'in the absence of an express retroactivity provision, a statute will not be applied retroactively unless it is very clear from extrinsic sources that the Legislature [or electorate] ... must have intended a retroactive application.' [Citations.] Accordingly, ' "a statute that is ambiguous with respect to retroactive application is construed ... to be unambiguously prospective." ' [Citation.]" (

22
People v. Hajek and Vogreen
cal · 2014 · cited in 10 California opinions naming this issue, 2016–2017
2 sentences

2017Section 3 specifies that no part of the Penal Code “is retroactive, unless expressly so declared.” This language “erects a strong presumption of prospective operation, codifying the principle that, ‘in the absence of an express retroactivity provision, a statute will not be applied retroactively unless it is very clear from extrinsic sources that the Legislature [or electorate] . . . must have intended a retroactive application.’ [Citations.] Accordingly, ‘ “a statute that is ambiguous with respect to retroactive application is construed ... to be unambiguously prospective.” ’ [Citation.]” (Pe

2017Section 3 specifies that no part of the Penal Code “is retroactive, unless expressly so declared.” This language “erects a strong presumption of prospective operation, codifying the principle that, ‘in the absence of an express retroactivity provision, a statute will not be applied retroactively unless it is very clear from extrinsic sources that the Legislature [or electorate] . . . must have intended a retroactive application.’ [Citations.] Accordingly, ‘ “a statute that is ambiguous with respect to retroactive application is construed ... to be unambiguously prospective.” ’ [Citation.]” (Pe

110
People v. Rangelgreen
cal · 2016 · cited in 8 California opinions naming this issue, 2016–2017
2 sentences

2017Section 3 specifies that no part of the Penal Code “is retroactive, unless expressly so declared.” This language “erects a strong presumption of prospective operation, codifying the principle that, ‘in the absence of an express retroactivity provision, a statute will not be applied retroactively unless it is very clear from extrinsic sources that the Legislature [or electorate] . . . must have intended a retroactive application.’ [Citations.] Accordingly, ‘ “a statute that is ambiguous with respect to retroactive application is construed ... to be unambiguously prospective.” ’ [Citation.]” (Pe

2017Section 3 specifies that no part of the Penal Code “is retroactive, unless expressly so declared.” This language “erects a strong presumption of prospective operation, codifying the principle that, ‘in the absence of an express retroactivity provision, a statute will not be applied retroactively unless it is very clear from extrinsic sources that the Legislature [or electorate] . . . must have intended a retroactive application.’ [Citations.] Accordingly, ‘ “a statute that is ambiguous with respect to retroactive application is construed ... to be unambiguously prospective.” ’ [Citation.]” (Pe

18
People v. Collinsgreen
cal · 1986 · cited in 1 California opinions naming this issue, 2002–2002
1 sentence

2002(Chi Ko Wong, supra, 18 Cal.3d at p. 716 & fn. 14.) Announcing a rule with only a prospective effect thus preserved the right to challenge important rulings on appeal by a defendant “ ‘who did all that was necessary to comply with the law applicable at the time of his trial.’ ” (Collins, supra, 42 Cal.3d at p. 389.) Fundamental fairness does not require a prospective-only rule here, however.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in California. Read the followed side critically anyway.

Also cited on this issue (2)

CaseCitedYears
In Re Estrada green
cal · 1965
2 sentences

2017Section 3 specifies that no part of the Penal Code “is retroactive, unless expressly so declared.” This language “erects a strong presumption of prospective operation, codifying the principle that, ‘in the absence of an express retroactivity provision, a statute will not be applied retroactively unless it is very clear from extrinsic sources that the Legislature [or electorate] . . . must have intended a retroactive application.’ [Citations.] Accordingly, ‘ “a statute that is ambiguous with respect to retroactive application is construed ... to be unambiguously prospective.” ’ [Citation.]” (Pe

2017Section 3 specifies that no part of the Penal Code “is retroactive, unless expressly so declared.” This language “erects a strong presumption of prospective operation, codifying the principle that, ‘in the absence of an express retroactivity provision, a statute will not be applied retroactively unless it is very clear from extrinsic sources that the Legislature [or electorate] . . . must have intended a retroactive application.’ [Citations.] Accordingly, ‘ “a statute that is ambiguous with respect to retroactive application is construed ... to be unambiguously prospective.” ’ [Citation.]” (Pe

162015–2017
People v. Chi Ko Wong green
cal · 1976
1 sentence

2002(Chi Ko Wong, supra, 18 Cal.3d at p. 716 & fn. 14.) Announcing a rule with only a prospective effect thus preserved the right to challenge important rulings on appeal by a defendant “ ‘who did all that was necessary to comply with the law applicable at the time of his trial.’ ” (Collins, supra, 42 Cal.3d at p. 389.) Fundamental fairness does not require a prospective-only rule here, however.

12002–2002

Statutes the citing opinions construe

CA § Cal. Health and Safety Code § 11361.5 (11) CA § Cal. Penal Code § 1170.18 (9) CA § Cal. Health and Safety Code § 11377 (6) CA § Cal. Penal Code § 1170.126 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 18 (2002–2017) MA 2 (2007–2015)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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