People v. The North River Ins. Co., 69 Cal.App.5th 1079

North River Insurance (surety) and Bad Boys Bail Bonds (bail agent) posted a $35,000 bond for Jamar Saunders in Oct. 2017; Saunders failed to appear and the court declared forfeiture.
The court granted extensions/tolling of the 180-day appearance period multiple times; the combined period expired Sept. 13, 2019.
Saunders was returned to custody and appeared in Los Angeles court on July 15, 2019 (within the extended/tolled appearance period), pleaded no contest, and was sentenced. The minutes/transcript do not show the court vacating the forfeiture and exonerating the bond at that time.
On Dec. 13, 2019 the court ordered Bad Boys to pay $6,118.78 in extradition costs; after no payment, the court entered summary judgment May 15, 2020 against Bad Boys for that amount plus administrative costs and interest.
North River parties appealed, arguing the bond had been exonerated by operation of law when Saunders appeared and therefore the court lacked jurisdiction to impose costs or enter summary judgment; the Court of Appeal reversed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the bond remained enforceable after Saunders appeared in custody during the appearance period	The People: court can condition relief and later enforce unpaid costs; prior cases permit conditioning relief before exoneration	North River: appearance within appearance period automatically vacates forfeiture and exonerates bond; any later orders are void for lack of jurisdiction	Bond was exonerated by operation of law when Saunders appeared; subsequent orders/judgment were void for lack of jurisdiction
Whether the court could impose extradition costs after the bond was exonerated	The People: §1306(b) allows imposition of costs as condition of relief and summary judgment for nonpayment	North River: once exonerated by operation of law, no basis remains to impose costs or enter summary judgment	Court could not lawfully impose the Dec. 13, 2019 costs or enter summary judgment because those orders assumed a non‑existent bond; costs could only have been conditioned at time of relief but were not
Whether summary judgment could properly name Bad Boys Bail Bonds (the bail agent)	The People: entry against the named party was an error that could be corrected by remand	North River: naming is improper and moot because bond was exonerated	Naming Bad Boys is moot given automatic exoneration; the judgment is reversed

People v. Financial Casualty & Surety, Inc., 2 Cal.5th 35 (2016) (describes bail as contract and the purpose of forfeiture; explains relief on forfeiture).
People v. Safety National Casualty Corp., 62 Cal.4th 703 (2016) (forfeiture is a remedy for surety breach when defendant fails to appear).
People v. Indiana Lumbermens Mut. Ins. Co., 49 Cal.4th 301 (2010) (if defendant appears within appearance period, court must vacate forfeiture and exonerate bond).
People v. American Contractors Indemnity Co., 33 Cal.4th 653 (2004) (trial court may extend or toll appearance period; exoneration rules explained).
People v. The North River Ins. Co., 53 Cal.App.5th 559 (2020) (strict construction of forfeiture statutes in favor of surety; summary judgment rules after forfeiture).
People v. National American Ins. Co., 32 Cal.App.4th 1176 (1995) (addressed conditioning relief under an earlier statutory regime; distinguished here as decided under former law).
People v. Accredited Surety & Casualty Co., 26 Cal.App.5th 913 (2018) (reversed summary judgment where defendant appeared within exoneration period; bond exonerated by operation of law).