People v. Littlefield, 24 Cal. App. 5th 1086

Littlefield pled guilty to one count of forgery and was sentenced on January 5, 2000, to 16 months; the court ordered victim restitution to three victims totaling several thousand dollars.
A $200 restitution fine was stayed contingent on payment of victim restitution.
On July 20, 2016 Littlefield received a collection demand from the Franchise Tax Board seeking payment of $8,416.94; Littlefield alleged the amount and collection action were improper.
On December 15, 2016, while no longer in custody, Littlefield filed a pro per motion in the criminal case asking the trial court to vacate the victim restitution order under the doctrine of laches, citing delay in enforcement and his recent medical and financial hardship.
The trial court concluded it lacked jurisdiction to entertain the motion and referred Littlefield to civil remedies; Littlefield appealed the denial on January 18, 2017.
The appellate court dismissed the appeal, holding the trial court lacked post-judgment authority to vacate the restitution order and that the order denying relief was non-appealable.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the criminal trial court had jurisdiction to vacate or modify a victim restitution order many years after sentencing and after Littlefield served his sentence	Littlefield: court retains jurisdiction under statutes (esp. §1202.46) and under Ford to modify or vacate restitution; laches provides equitable relief because enforcement was stale and would cause hardship	People/AG: statutes relied on do not authorize a defendant to erase a valid restitution obligation years after sentence execution; laches is an equitable defense inappropriate in criminal postjudgment relief; trial court lacked authority	Court: trial court lacked jurisdiction to vacate restitution after execution of sentence; §§1202.46 and 1214 do not authorize defendant relief; Ford and Turrin do not support vacatur here
Whether the order denying Littlefield's motion was appealable	Littlefield: appealed the trial court's denial	People/AG: because the trial court lacked jurisdiction, the denial did not affect substantial rights and is not an appealable postjudgment order	Court: denial was non-appealable; appeal dismissed

People v. Ford, 61 Cal.4th 282 (Cal. 2015) (discusses limits of jurisdiction and estoppel where defendant consented to continued restitution proceedings)
People v. Turrin, 176 Cal.App.4th 1200 (Cal. Ct. App. 2009) (trial court lacked jurisdiction to modify restitution fines after execution of sentence; limited exceptions described)
People v. Dynes, 20 Cal.App.5th 523 (Cal. Ct. App. 2018) (order denying certain postjudgment criminal relief is non-appealable)
People v. Mendez, 209 Cal.App.4th 32 (Cal. Ct. App. 2012) (dismissal of appeal from denial of late motion to reduce restitution fine where sentence execution had begun)
People v. Howard, 16 Cal.4th 1081 (Cal. 1997) (general principle that court loses jurisdiction to modify sentence after execution has begun)