The Supreme Court today granted Governor Gavin Newsom’s request for a recommendation to commute Robert Strickland’s 1995 sentence of 89 years to life for robbery and attempted robbery as a third strike with sentence enhancements. The commutation would make Strickland eligible for an earlier parole suitability hearing.

Newsom asked in February for the recommendation, which is constitutionally required before he can grant clemency to anyone, like Strickland, who has been “twice convicted of a felony.”

The court has said it reviews clemency recommendation requests under a deferential standard. (See here and here.) And Newsom has a nearly perfect record — he withdrew one request before a ruling, but the court has approved all 45 of his other requests. That’s better than former Governor Jerry Brown, who had the court without explanation block 10 intended clemency grants.

Because no one filed a motion to unseal, the Strickland clemency record will remain confidential.