Four years ago these guys argued that California Governor Gavin Newsom’s moratorium on executions was a limited and temporary stopgap that raised separation-of-powers issues, exceeded executive power, and undermined the electorate’s will. Little has changed since then, with the executive order still in place, capital appeals proceeding apace, and no one being executed. Now we expand on the solution briefly posited in the previous article: the governor can and should seek judicial approval to commute all death sentences to life without parole.