People v. Hahn, 16 Cal. App. 5th 349

In 2010 Hahn pled guilty to felony possession (Health & Saf. Code § 11377(a)); placed on deferred entry then formal probation.
In April 2015 the court resentenced him to a misdemeanor and terminated probation after he admitted a violation, imposing a 120‑day jail term but staying execution to allow work‑furlough screening and to report on May 4, 2015.
Hahn had a history of failing to appear at mandatory hearings and requested the later reporting date; the court granted that request despite the history.
Hahn failed to report on May 4, 2015; he was arrested on a warrant July 27, 2016 and brought before the court.
The trial court ruled it lacked jurisdiction to remand him after probation termination, deleted the 120‑day sentence, and discharged Hahn; the People appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether court retained power to enforce a stayed jail term after probation termination	Court retained jurisdiction while execution was stayed and can enforce judgment	Court lacks jurisdiction to remand once probation terminated	Reversed: court retained power to execute the stayed sentence and must reinstate it
Whether termination of probation extinguishes sentence enforcement power	Termination does not affect court's power to carry judgment into effect	Termination deprives court of power to remand	Held for People: termination irrelevant to enforcement of an independently imposed jail term
Whether defendant waived/estopped from objecting to enforcement by requesting the stay and failing to appear	Defendant’s request for a delayed report and subsequent failure to appear estops objection	Defendant argues lack of jurisdiction regardless of his conduct	Court held Hahn estopped/waived his right to complain because his conduct caused delay
Whether court must retain means to compel compliance (inherent/injunctive power)	Court has inherent and statutory power to compel obedience to its orders (Code Civ. Proc. §128)	If not, stays would create unenforceable orders or force undesirable probation retention	Held: court has power to enforce stays and may use suitable processes to carry judgment into effect

People v. Gooch, 33 Cal.App.4th 1004 (court does not lose jurisdiction while execution is stayed)
People v. Karaman, 4 Cal.4th 335 (execution of judgment is carrying the judgment into effect)
In re Bakke, 42 Cal.3d 84 (probation orders generally modifiable only during probation; waiver can permit enforcement after expiration)
People v. Ham, 44 Cal.App.3d 288 (defendant estopped to object when requesting continuance beyond probation term)
In re Clark, 70 Cal.App. 643 (court must retain power to enforce sentence after a defendant-requested stay)