People v. Maya, 460 P.3d 1216

Misael Vences Maya pleaded guilty to DUI (with prior convictions) and felony possession; he received prison time with no probation.
Maya completed his state prison term in 2012 and has remained in federal immigration custody since then.
While in immigration custody, Maya obtained a reduction of the felony possession conviction to a misdemeanor under Penal Code section 1170.18.
Maya petitioned to expunge the misdemeanor under Penal Code § 1203.4a(a), which permits expungement if the defendant has, among other things, “since the pronouncement of judgment, lived an honest and upright life.”
The district attorney and the trial court denied relief, reasoning that being in custody does not equate to living an honest and upright life and that there was no opportunity to demonstrate law‑abiding behavior outside custody; the Court of Appeal affirmed.
The California Supreme Court granted review to decide whether conduct while in custody can be considered in the “honest and upright life” inquiry and ultimately held such conduct is relevant and may satisfy the requirement; it reversed the Court of Appeal and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether conduct while in custody can count toward the § 1203.4a(a) requirement that the defendant has “since the pronouncement of judgment, lived an honest and upright life.”	Custodial time is not equivalent to living an honest and upright life; no opportunity to be evaluated while incarcerated.	The statute’s phrase “since the pronouncement of judgment” includes time in custody; in‑custody conduct is relevant and can satisfy the requirement.	The Supreme Court held custodial conduct is relevant and, in appropriate cases, can satisfy the statutory “honest and upright life” requirement; reversed and remanded.

People v. Maya, 33 Cal. App. 5th 266 (Cal. Ct. App. 2019) (Court of Appeal decision addressing whether custodial behavior is relevant to § 1203.4a(a); Supreme Court reviewed and reversed its categorical rule.)