People v. Woods
D070477
| Cal. Ct. App. | Jun 7, 2017Background
- Defendant Marsha Woods, on probation for two prior cases (Case 699 and Case 042), was arrested in 2015 for theft and possession of methamphetamine; she faced five charges and multiple prior allegations.
- Plea agreement: defendant would plead to attempted burglary, admit one strike and probation violations, and receive concurrent sentences — 16 months on the current case and seven years on each probation case; remaining charges dismissed.
- Trial court accepted the plea and referred sentencing for presentence reports; the probation department submitted conflicting custody-credit calculations (dispute whether full day-for-day credits under §4019 or reduced credits under §2933.1 applied).
- At sentencing, after expressing frustration with the credit calculations, the trial court imposed the stipulated 16-month term on the current case but "terminated" probation on the two prior cases instead of imposing the agreed seven-year concurrent terms, reasoning the seven years were "just about eaten up by credits."
- The People appealed, arguing the sentence departed from the plea bargain. Defendant argued forfeiture of the claim, or that she had already served enough credits to satisfy the seven-year terms (making the issue moot).
- The Court of Appeal concluded the trial court violated the plea bargain, rejected forfeiture and defendant's credit/mootness arguments, reversed, and remanded with directions to either (a) impose the bargain sentence (after calculating and recording custody credits) or (b) withdraw approval of the plea and restore the status quo ante.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Forfeiture — Did People forfeit appellate challenge by failing to object at sentencing? | People argue their objection at sentencing ("she should be getting the seven years") preserved the claim. | Woods contends People forfeited by not explicitly objecting that the court deviated from the plea. | Preserved: prosecutor's on-the-record statement sufficiently preserved the issue for appeal. |
| Prejudice / Mootness — Has defendant already served the seven-year terms via custody credits? | People argue the court erred and relief is required; defendant has not actually served seven years on each probation case. | Woods claims probation department credits total >3,100 days (over seven years) so People suffered no prejudice or claim is moot. | Rejected defendant's calculation as double-counting overlapping custody days; she had not served seven years on either sentence, so claim is not moot and prejudice may exist. |
| Plea-bargain breach — Could the court terminate probation instead of imposing the agreed seven-year terms? | People: court was bound to impose sentence within plea bargain once it accepted plea. | Woods: (implicit) court discretion and credits justify termination or equivalent effect. | Court breached plea bargain by enforcing part of the agreement (16 months) while ignoring the stipulated seven-year terms; court must either enforce the bargain or withdraw it entirely. |
| Remedy on remand — What must the trial court do? | People seek enforcement of plea or restoration of status quo to allow reinstatement of charges. | Woods seeks no change because she argues credits already satisfy the seven years. | Remand: trial court must either (1) calculate/record custody credits and sentence in accordance with plea, or (2) withdraw approval of the plea and restore parties to status quo ante (allowing People to reinstate dismissed charges). |
Key Cases Cited
- People v. Segura, 44 Cal.4th 921 (2008) (plea bargains are contracts; court bound to impose sentence within bargain)
- In re Ricardo C., 220 Cal.App.4th 688 (2013) (plea bargain as contract; if court withdraws approval it must restore status quo ante)
- People v. Armendariz, 16 Cal.App.4th 906 (1993) (court approval binds court to plea terms)
- People v. Panizzon, 13 Cal.4th 68 (1996) (both parties entitled to benefit of plea bargain)
- People v. Kim, 193 Cal.App.4th 1355 (2011) (available remedies when plea bargain benefits are denied)
- People v. Collins, 21 Cal.3d 208 (1978) (relief for deprivation of bargained concessions)