People v. Arroyo

LIU, J.,

Concurring.—I agree with today’s opinion that Welfare and Institutions Code section 707, subdivision (d)(4) does not require prosecution by way of a preliminary hearing before a magistrate in discretionarily filed cases under section 707, subdivision (d)(2). I also agree that because “ ‘the grand jury serves as the functional equivalent of a magistrate who presides over a preliminary examination on a felony complaint’ ” (Guillory v. Superior Court (2003) 31 Cal.4th 168, 174 [1 Cal.Rptr.3d 879, 72 P.3d 815]), the grand jury must make a finding “that reasonable cause exists to believe…