Davis, 67, still has at least two hurdles, the California Department of Corrections and Rehabilitation said in a release. The Board of Parole Hearings has 120 days to review its recommendation and the final decision is in the hands of Gov. Arnold Schwarzenegger.
Davis was convicted with Charles Manson of killing Gary Hinman, an acquaintance Manson believed had money, and Donald "Shorty" Shea, an employee at the family's hideout, the Spahn Movie Ranch in Chatsworth, Calif. Davis was not charged with the Manson family's most notorious crimes -- the killing of actress Sharon Tate, wife of director Roman Polanski, and three of her friends, and of Leno and Rosemary LaBianca.
The department said Davis is currently being held in the California Men's Colony in San Luis Obispo and has had no disciplinary infractions since 1980. He has participated in educational and therapeutic programs at the prison.