People v. Trujillo, 60 Cal. 4th 850

Defendant Trujillo convicted of felony receiving stolen property and placed on probation; trial court ordered restitution and various fines/fees including presentence investigation fee (<= $300) and probation supervision fee (<= $110/month) under Penal Code §1203.1b.
Probation officer prepared the presentence report without defendant's interview because she invoked the Fifth Amendment; no on-the-record waiver of the right to a court hearing under §1203.1b appears in the record.
Defense counsel received the report and raised no objection at sentencing; defendant did not assert inability to pay or seek a hearing either at sentencing or in probation department (record ambiguous whether she complied with the Department of Revenue order).
On appeal defendant challenged the booking fee (forfeited under People v. McCullough) and argued the court failed to follow §1203.1b procedures before imposing presentence and probation supervision fees.
Court of Appeal reversed and remanded for compliance with §1203.1b; the Supreme Court granted review to decide whether the forfeiture rule applies to challenges based on noncompliance with §1203.1b.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defendant forfeited appellate challenge to imposition of presentence investigation and probation supervision fees under §1203.1b by not objecting below	The People: forfeiture rule from sentencing context (and McCullough re: booking fee) applies; defendant should have raised noncompliance at sentencing	Trujillo: §1203.1b requires an express knowing and intelligent waiver and procedural safeguards, so lack of waiver is clear legal error reviewable on appeal despite forfeiture	Held: Forfeiture applies. Defendant forfeited the appellate challenge; failure to object at sentencing bars review of §1203.1b noncompliance (Court affirmed in part, reversed only as to clerical minute order corrections).

People v. McCullough, 56 Cal.4th 589 (discusses forfeiture of appellate challenge to booking fee and reasons to apply forfeiture in fee context)
People v. Scott, 9 Cal.4th 331 (explains forfeiture doctrine for sentencing discretion and distinction between factual sentencing errors and clear legal errors)
People v. Welch, 5 Cal.4th 228 (held objections to probation conditions are forfeited if not raised at trial)
In re Sheena K., 40 Cal.4th 875 (general principle that rights may be forfeited by failure to timely assert them)
Boykin v. Alabama, 395 U.S. 238 (establishes that waivers of significant constitutional rights require on-the-record assurances)
Faretta v. California, 422 U.S. 806 (requires on-the-record advisement for waiver of right to counsel)
People v. Valtakis, 105 Cal.App.4th 1066 (Court of Appeal decision holding §1203.1b noncompliance claim forfeited)