An unauthorized sentence does not confer jurisdiction on a trial court to modify a final judgment. The Court of Appeal followed People v. Boyd (2024) 103 Cal.App.5th 56, and disagreed with People v. Codinha (2023) 92 Cal.App.5th 976, in holding that correcting an unauthorized sentence is only possible where the court otherwise has jurisdiction. Here, a letter from a CDCR case manager did not satisfy the jurisdictional requirements of PC 1172.1(a)(1). Accordingly, the higher sentence which the trial court imposed by fixing the error was void and the original sentence was reinstated.
The full opinion is available on the court’s website here: https://www4.courts.ca.gov/opinions/documents/B341793.PDF
