Napa Citizens for Honest Government v. Napa County Board of Supervisors

In 1994 and thereafter, the Legislature established and amended a special supplementary statute of limitations for certain sex crimes against minors. (Pen. Code, § 803, subd. (g) (section 803(g)).) Under specified circumstances, the 1994 law, as more recently refined, revives the limitations period for such offenses after the usual statute of limitations has expired, even if both the crime, and expiration of the usual limitations period, occurred before 1994. We found that these retroactive features did not offend either ex post facto or due process principles in People v. Frazer (1999) 21 Cal.4th 737 (Frazer) (cert. den. sub nom. Frazer v. California (2000) 529 U.S. 1108, rehg. den. (2000) 530 U.S. 1284).