Governor Newsom last week asked the Supreme Court’s permission to grant four pardons. A court recommendation is a constitutional prerequisite for a gubernatorial grant of clemency to anyone who has been “twice convicted of a felony.”
The four, with their criminal records as stated in the Governor’s cover letters to the court, are:
Phi Le: “In 1991, Mr. Le was convicted of assault with a firearm on a person. In 1994, Mr. Le was convicted of second degree robbery. In 2025, Mr. Le’s conviction was withdrawn and vacated, the complaint was reinstated, Mr. Le was convicted of kidnapping and false imprisonment, and his sentence was deemed served.”
Laura Rodriguez: “In 1996, Ms. Rodriguez was convicted of second degree robbery. In 2007, Ms. Rodriguez was convicted of possessing an identification card to commit forgery.”
Jose Moran: “In 1995, Mr. Moran was convicted of receiving known stolen property, the transport or sale of a controlled substance, and possession of a controlled substance while armed with a loaded firearm.”
Hillena Beyene: “In 1992 and 1997, Mr. Beyene was convicted of drug-related felony offenses. In 1998, Mr. Beyene was convicted of vehicle theft, and in 2006, he was convicted of grand theft.”
Newsom has a nearly perfect clemency record: he withdrew one request before a ruling, but the court — applying a deferential standard (see here and here) — has approved all 98 of his other requests (not counting pending requests). That’s better than former Governor Jerry Brown, who had the court without explanation block 10 intended clemency grants. The denial of a request implies that a clemency grant would be an abuse of power.
The Governor’s requests were filed under seal. They will remain shielded from the public unless someone moves to unseal the records. If a motion is filed, the court will likely require Newsom to justify keeping all or part of the records under wraps and will then probably make redacted records available for viewing. (See here and here, and recently, here.) Requests to recommend commutation of life without parole sentences often draw unseal motions from the San Bernardino County District Attorney’s Office.
