Imposing multiple restitution fines (PC 1202.4(b)) in one case is error requiring remand for reconsideration even when the aggregate total is below the statutory maximum. Here, the trial court imposed a $5,000 fine on count one and a $300 fine on count two. Disagreeing with People v. Sencion (2012) 211 Cal.App.4th 480, which found such an error harmless, the Court of Appeal found “no clear indication” the trial court would have ordered the same $5,300 total amount “had it understood the statutory direction to impose a single fine.”

The full opinion is available on the court’s website here: https://www4.courts.ca.gov/opinions/documents/C102305.PDF