People v. Financial Casualty & Surety, 211 Cal. Rptr. 3d 79

Financial Casualty posted a $1,240,000 bail bond for Oscar Grijalva; Grijalva failed to appear and a notice of forfeiture was mailed Aug 24, 2012, triggering a 185‑day appearance period ending Feb 25, 2013.
Financial Casualty timely moved under Penal Code §1305.4 to extend the period; investigator McGuire detailed extensive but fruitless investigative efforts and led to a March 20, 2013 order extending the period to Aug 1, 2013.
Financial Casualty moved again on Aug 1, 2013 for a further extension (seeking up to Sept 16, 2013); McGuire’s second declaration reported additional leads but omitted predictions about likelihood of capture.
On Aug 26, 2013 the trial court denied the second extension (stating doubt both about jurisdiction to extend and about good cause), and later entered summary judgment on the bond.
The Court of Appeal affirmed, reasoning (1) the surety failed to show a reasonable likelihood an extension would produce apprehension, and (2) under some precedents the 180‑day extension window was measured from the original forfeiture date (raising doubt about authority to extend).
The Supreme Court held: the trial court had statutory authority to grant extensions measured from the court’s extension order (not the forfeiture date), but the court did not abuse its discretion in denying the further extension because the surety failed to show a reasonable likelihood the extension would produce Grijalva’s return.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 180‑day extension under §1305.4 is measured from the end of the initial appearance period or from the court’s extension order	Measured from the end of the initial appearance period (so total cannot exceed 365 days)	Measured from the date of the court’s extension order (so 180 days runs from that order)	Measured from the court’s extension order; but the 180‑day cap is 180 days from the first extension order (no unlimited serial renewals).
Whether good cause for an extension requires showing a reasonable likelihood the extension will lead to apprehension, and who bears the burden	Court may require prospective showing; burden on surety to prove good cause	Past diligence alone suffices; shifting burden to surety to prove likelihood is unfair/impracticable	A court may consider likelihood of apprehension as part of good cause; burden remains on the surety to show good cause (including reasonable likelihood when relevant). The trial court did not abuse discretion denying the extension here.

People v. Taylor Billingslea Bail Bonds, 74 Cal.App.4th 1193 (1999) (interpreting pre‑1999 law to limit total extension to 180 days past initial period)
People v. American Contractors Indemnity Co., 33 Cal.4th 653 (2004) (describing nature and purpose of bail and forfeiture)
People v. Accredited Surety & Casualty Co., 137 Cal.App.4th 1349 (2006) (holding good cause requires both diligence and reasonable likelihood of securing defendant)
County of Los Angeles v. Fairmont Specialty Group, 164 Cal.App.4th 1018 (2008) (same good‑cause framework; low threshold but prospective inquiry permitted)
People v. Ranger Ins. Co., 81 Cal.App.4th 676 (2000) (upholding denial where declaration failed to show diligence or realistic prospect of apprehension)
People v. Alistar Ins. Co., 115 Cal.App.4th 122 (2003) (extension granted where diligence plus plausible showing of ability to return defendant supported relief)