People v. Rockwell CA4/2, E082777

Jeremy Jay Rockwell pled guilty in 2019 to seven felonies related to domestic violence, threats, and resisting police, in exchange for dismissal of rape and mayhem charges.
He was sentenced to a total of 13 years and 8 months (12 years, 8 months in prison plus a consecutive 364 days in county jail for a misdemeanor battery count).
Rockwell later requested recalculation of his presentence custody credits, arguing for more credits under Penal Code §4019 instead of the violent felony limitation under §2933.1; the trial court denied his request.
He separately sought amendment of the judgment to serve his misdemeanor sentence in state prison rather than county jail, citing health, safety, and rehabilitation needs as a transgender person and referencing Senate Bill 132.
Both postjudgment motions were denied, and on appeal, his counsel filed a no-issue (Delgadillo) brief; Rockwell supplemented raising additional issues regarding the misdemeanor sentencing authority.
The appellate court considered the matters but found all claims either non-appealable or, even if reviewable, without legal merit.

Issue	Rockwell's Argument	State's Argument	Held
Presentence Custody Credits	Credits should be recalculated under §4019 (higher credits).	Violent felony with GBI enhancement triggers §2933.1, limiting credits.	Denial affirmed; court lacked jurisdiction, and statute limits apply.
Serving Misdemeanor Sentence in Prison	Requests serving 364-day battery term in prison (not jail) for health/safety/rehabilitation as transgender person under SB 132.	No statutory authority or changed circumstances to amend sentence; administrative channels not exhausted.	Denial affirmed; no mechanism for such relief and issue is unripe.
Jurisdiction to Revisit Sentencing	Claims postjudgment orders are appealable.	Orders not appealable; trial court lost jurisdiction after sentence commenced.	Agreed with State; no appealable order or basis for relief.
Maximum Sentence for Battery Misdemeanor	364-day sentence exceeded statutory maximum for battery (claims only 6 months allowed).	Statute allows up to 1 year for domestic violence battery (§243(e)(1)).	No error in original sentence; statutory authority supported court action.

People v. Johnson, 123 Cal.App.3d 106 (Cal. Ct. App. 1981) (sets standard for what constitutes an 'arguable issue' on appeal)
People v. Scott, 9 Cal.4th 331 (Cal. 1994) (defines "unauthorized sentence" exception to the preservation requirement)
In re Pacheco, 155 Cal.App.4th 1439 (Cal. Ct. App. 2007) (GBI enhancement limits custody credits)