S.B. 775 was passed in response to appellate court decisions that had held Penal Code section 1170.95 did not apply to attempted murder convictions. S.B. 775 expressly states that the bill now “clarifies” that section 1170.95 does apply to both attempted murder and voluntary manslaughter convictions under a felony murder or natural and probable consequences theory. The Legislative history confirms that S.B. 775 was enacted in part to abrogate appellate decisions that had concluded that attempted murder and voluntary manslaughter convictions were ineligible for section 1170.95 relief.
Read more: https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202120220SB775