People v. Camp
233 Cal. App. 4th 461
| Cal. Ct. App. | 2015Background
- Camp pleaded guilty to grand theft from a person and resisting an officer, with a split sentence of 28 months: 14 months in local custody and 14 months under mandatory supervision.
- Before release, ICE indicated Camp was illegally in the U.S. and would be deported, making him unavailable for mandatory supervision.
- Defense moved to terminate mandatory supervision so Camp could be deported; the trial court terminated it and released Camp to ICE.
- The People appealed contending the court lacked jurisdiction to terminate mandatory supervision and modify the sentence.
- The appellate court affirmed the trial court, ruling there was statutory authority to terminate mandatory supervision and modify the sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court had jurisdiction to terminate mandatory supervision without requiring custody. | People argues termination creates an unauthorized sentence. | Camp contends the court acted within statutory authority to terminate supervision. | Court possessed jurisdiction to terminate mandatory supervision and modify the sentence. |
| Whether termination complied with the Realignment Act and related statutes governing probation and mandatory supervision. | People relies on Dix and Howard to claim no authority to modify after execution. | Camp asserts statutory framework allows modification under 1203.2/1203.3 for mandatory supervision. | Statutory framework permits modification; termination did not violate the Realignment Act. |
| Whether modification violated the plea agreement. | People contend the court’s action thwarted the plea terms. | Camp argues the modification was within statutory authority and plea terms were not effectively altered. | Termination/modification did not breach the plea agreement. |
Key Cases Cited
- Doe v. Brown, 177 Cal.App.4th 408 (Cal. Ct. App. 2009) (statutory interpretation uses ordinary meaning and context; de novo review)
- People v. Howard, 16 Cal.4th 1081 (Cal. 1997) (distinguishes suspension of imposition vs. execution; probation context)
- People v. Rahbari, 232 Cal.App.4th 185 (Cal. Ct. App. 2014) (mandatory realignment akin to probation; applicability of probation revocation procedures)
- People v. Scott, 58 Cal.4th 1415 (Cal. 2014) (Realignment Act applicability to probation before operative date; scope of term 'sentenced')
- Segura v. People, 44 Cal.4th 921 (Cal. 2008) (plea bargains incorporate existing law; court cannot modify plea terms unilaterally)
- Leiva v. People, 56 Cal.4th 498 (Cal. 2013) (probation authority to revoke/modify; statutory interpretation of discretion)