Two strikes based on the same set of facts? “Not anymore” says California’s Supreme Court as they clarify the language of the 31-year-old Three Strikes Law. 

In the case of Troy Lee Shaw, the Court handed down its interpretation of the qualifying second and third strikes. 

In December of 2025 the California Supreme Court determined that an offender must have two separate failed attempts at reform before receiving a harsher sentence. The Court used the baseball analogy — a defendant does not get two strikes with one swing of the bat. 

“The language of California Supreme Court in People v. Shaw is so broad in its application, it seems judges are trying to right a wrong,” said San Quentin resident Tyrone D. Jones, 46, incarcerated for 26 years under the Three Strikes Law.

In 2002, Shaw was convicted of two counts of vehicular manslaughter. Eighteen years later, he received a 25-year-to-life sentence after facing drug possession charges that were weighed in hand with his former convictions.

In the Shaw decision, the Court stated if there were two offenses committed in a sequence against two victims, it counts as one strike. The High Court added that if there were one victim in the same set of facts resulting in multiple felonies, it counts as one strike.

In his concurring opinion with the Court’s majority, Justice J. Groban stated that the aim of the Three Strikes Law was to discourage recidivism and focus on reform.

In its decision, the Court cited its 1998 ruling in People v. Benson. The defendant was convicted of two prior felonies for residential burglary and assault with the intent to commit murder. He entered his neighbor’s home unlawfully and stabbed her.

In the Benson case, the Court determined that when multiple convictions arise out of a single act, the trial court should have dismissed one strike.

The decision also cited the 2014 case People v. Vargas, in which the defendant had a previous conviction of robbery and carjacking; both convictions arose out of the same set of facts. The Court agreed to review the Vargas case to see if the trial court should have dismissed one of the priors. 

In 1994, California voters enacted the Three Strikes Law in response to the high profile murders of Polly Klaas and Kimber Reynolds, which were committed by previously convicted felons, according to Stanford Law School.

The law’s objective was to punish repeat offenders by removing them from society using lengthy prison terms. Six months after the enactment of the law, there were 7,400 second-strike and third-strike cases filed statewide, according to the Legislative Analyst’s Office.

In California’s criminal justice history, more than 90 percent of felony prosecutions were plea bargains. The guilty pleas dropped significantly since the enactment of the three-strikes, defendants have refused to entertain plea bargains, opting to take their cases to jury trial, when facing a mandatory minimum of 25-years-to-life, noted by the LAO.

CDCR statistics reveal that the Three Strikes Law has disproportionately affected defendants who are African American, mentally ill, and physically disabled.

In 2012, California voters modified the Three Strikes Law with Proposition 36 to eliminate non-serious and non-violent felonies that prompt a second and/or third strike. 

As a result, California released more than 1,000 incarcerated people. Stanford Law School reported that the recidivism rate of this group stood at less than 2%.

The California Supreme Court ruling has made its own modification of the Three Strikes Law, which may include previously excluded incarcerated people.

“People serving a Three Strikes sentence have been excluded from criminal justice reforms for many years,” Jones said. “I now feel vindicated.”