People v. Ford, 61 Cal. 4th 282

In 2008 William J. Ford pleaded no contest to felony hit-and-run, was granted three years probation, and the court reserved jurisdiction to determine additional restitution (lost wages) beyond an initial $12,465.88 award for medical expenses.
The probation term was extended multiple times (with Ford's consent) and ultimately expired March 30, 2012; a restitution hearing had been continued repeatedly at defense request or with defense consent.
The victim (Jennings) sought substantial lost-wage restitution after reconstructing business records; the trial court found a prima facie case for $275,017 and continued the hearing to allow defense rebuttal.
On March 27, 2012, the prosecutor was unavailable and Ford agreed to continue the hearing to April 6, 2012 — one week after his probation expired; on April 6 defense counsel made a special appearance contesting jurisdiction.
The trial court held it had jurisdiction to set restitution and ordered $275,017; the Court of Appeal affirmed, and the California Supreme Court granted review and affirmed on estoppel grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court retained power to fix/modify restitution after probation expired	People: court may order full restitution and retain jurisdiction under Penal Code provisions to determine restitution after sentencing	Ford: Penal Code §1203.3(b)(5) limits modifications to the probation term; because probation expired a week before the hearing, court lacked jurisdiction to set restitution	Court avoided deciding statutory jurisdiction question; held Ford is estopped from challenging jurisdiction because he consented to continuances that extended the hearing past probation expiration
Whether a party can be estopped from contesting jurisdiction when they consented to proceedings beyond ordinary authority	People: consent/continuances by defendant justify estoppel; plaintiff relied on prior authority allowing estoppel	Ford: argued absence of jurisdiction cannot be waived and he did not seek the continuance that caused the delay	Court: estoppel applies where defendant consented or failed to timely object; Ford’s conduct (requests, consents, failure to object) estops him from contesting jurisdiction

Simmons v. Ghaderi, 44 Cal.4th 570 (estoppel can bar later jurisdictional challenge when party sought or consented to action beyond court's power)
In re Bakke, 42 Cal.3d 84 (probation expiration does not terminate fundamental jurisdiction; party who consented to continuance beyond probation may be estopped)
In re Griffin, 67 Cal.2d 343 (weigh equities to determine estoppel where litigant requested continuance beyond statutory authority)
People v. American Contractors Indemnity Co., 33 Cal.4th 653 (distinguishes fundamental lack of jurisdiction from acts in excess of jurisdiction)