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Name: People v. Alford
Case #: A109478
Court: CA Court of Appeal
District 1 DCA
Division: 1
Opinion Date: 03/09/2006

Retroactive application of a statute imposing a court security fee is necessary to facilitate the legislation’s purpose of funding court security. The court agreed with the holding in People v. Wallace (2004) 120 Cal.App.4th 867 that the Legislature intended for the court security fee under Penal Code section 1465.8 to be imposed retroactively, and that this did not violate the ex post facto clause. The court further disagreed with People v. Carmichael (2006) 135 Cal.App.4th 937, which found that retroactive imposition violated Penal Code section 3, which imposes a statutory prohibition against retroactive application of penal laws.