rderers are often given parole hearings every
year. The families of murdered victims are never able to escape the seemingly
unending torture and fear that the murderer of their loved one will be once again
free to murder.‖ (2008 Voter Information Guide, supra, text of Prop. 9, § 2, at pp.
128–129.)



                                          12
protect a victim from harassment and abuse during the parole process, no person
paroled from a California correctional facility following incarceration . . . shall, in
the event his or her parole is revoked, be entitled to procedural rights other than
the following . . . .‖ (§ 3044, subd. (a), italics added.) Several of the enumerated
procedural rights are less protective of parolees than those previously adopted by
the federal district court in the 2004 stipulated order for injunctive relief. (See
2008 Voter Information Guide, supra, analysis of Prop. 9 by the Legis. Analyst, at
p. 60; Valdivia v. Brown, supra, 956 F.Supp.2d at pp. 1128–1129.) Of course, no
statute, whether enacted by the Legislature or by voter initiative, can circumvent
minimum constitutional protections. The Legislature‘s decision to set parolees‘
rights at Morrissey‘s constitutional baseline in section 1203.2 proceedings furthers
the purposes of Marsy‘s Law.
       Moreover, we may consider later statutory amendments in deciding the
validity of an implied amendment. (See People v. Ewoldt (1994) 7 Cal.4th 380,
390–393 (Ewoldt).) Here, two statutory amendments are significant. The first
was part of Proposition 47, the Safe Neighborhoods and Schools Act, enacted by
the voters on November 4, 2014. (Prop. 47, as approved by voters, Gen. Elec.
(Nov. 4, 2014) eff. Nov. 5, 2014.) That proposition added section 1170.18. It
allows someone serving a sentence for a crime that the proposition reduced to a
misdemeanor to petition for recall of the sentence. (§ 1170.18, subd. (a); Voter
Information Guide, Gen. Elec. (Nov. 4, 2014) text of Prop. 47, § 14, pp. 73–74.)
As relevant here, sectio