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An Update on Felony Murder Liability Under California Penal Code Section 1172.6

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July 27, 2023 @ 12:00 pm 1:00 pm

1 Hour MCLE; 1 Legal Specialization in Criminal Law  

This training will provide an overview and update on felony murder liability under California Penal Code section 1172.6. Effective January 1, 2019, the Legislature passed Senate Bill No. 1437 (2017-2018 Reg. Sess.) and thereby enacted Penal Code section 1172.6 (former section 1170.95). This new statute amended the felony murder rule and the natural and probable consequences doctrine to narrow murder liability. Prosecution under this statute is now limited to people who are actual killers, those who act with intent to kill, and those who are major participants in an underlying felony “who acted with reckless indifference to human life.” Since SB 1437’s enactment, significant changes have been made to the statute and governing case law in this constantly evolving area of law. 

Non-Member Price: $75.00
Member Price: $55.00

The Honorable Laura Passaglia was appointed to the Sonoma County bench as a Superior Court Commissioner in September 2021 and was assigned to the Criminal Division, presiding over a misdemeanor trial court for all purposes. In June 2022, Judge Passaglia was elected as a Sonoma County Superior Court Judge and was subsequently granted an interim appointment by Governor Gavin Newsom. Judge Passaglia continues to sit in the Criminal Division and currently presides over a criminal felony trial court for all purposes. Judge Passaglia has been a member of the CLA Criminal Law Section Executive Committee since 2019 and currently serves as the committee chair. 

Judge Passaglia received her undergraduate degree in political science from the University of California, Los Angeles. After earning her JD from The University of San Francisco School of Law in 2007, she joined the Alameda County District Attorney’s Office as Deputy DA where she prosecuted all manners of misdemeanor and felonies, including specialized assignments in the areas of domestic violence, homicide, human trafficking and sexual assault. Judge Passaglia joined the Sonoma County District Attorneys Office in 2017 where he resumed her work as a Felony trial prosecutor until appointed to the bench.  

Basil Williams is a Deputy Attorney General in the Appeals, Writs & Trials section of the California Department of Justice and a Lecturer at UC Berkeley School of Law. At California’s DOJ, Basil has argued complex felony cases in the California Supreme Court, the Ninth Circuit, and dozens of times in the state Court of Appeal. He has also briefed hundreds of cases in those courts and responds to habeas petitions in federal district court. Basil recently played a key role in helping to establish California’s first statewide Post Conviction Justice Unit within the Office of the Attorney General.  In addition to his state DOJ responsibilities, Basil dedicates substantial time to mentoring and teaching legal research, writing, and advocacy skills to law students at UC Berkeley. He has served as a member of the CLA Criminal Law Section Executive Committee since 2020.

Basil recently completed an MPA at Harvard University, where he was an Ash Fellow in Democracy. His studies focused on race, civil rights, and criminal justice reform. He also holds an LLM from the University of California College of the Law, SF (formerly UC Hastings) and an LLB from the University of London.

We are committed to accessibility! Virtual events are equipped with closed captioning. To request an in-person accommodation, send us a note at or contact us at 916-516-1760 for assistance.


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