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Name: People v. Boyd
Case #: E081005
Court: CA Court of Appeal
District 4 DCA
Division: 2
Opinion Date: 06/27/2024
Summary

The trial court lacked “fundamental jurisdiction” to hear defendant’s motion to correct error in calculating custody credits filed years after sentencing. The Court of Appeal follows People v. King (2022) 77 Cal.App.5th 629 in holding that an unauthorized sentence does not create trial court jurisdiction to correct the error, disagreeing with People v. Codinha (2023) 92 Cal.App.5th 976. Further, a sentence unauthorized in one respect (custody credits) does not require vacating the entire sentence or justify a full resentencing.

The full opinion is available on the court’s website here: https://www.courts.ca.gov/opinions/documents/E081005.PDF