Wofford v. Superior Court
230 Cal. App. 4th 1023
| Cal. Ct. App. | 2014Background
- Wofford challenged a superior court ruling denying permission to apply for an Interstate Compact transfer after Realignment mandatory supervision.
- Wofford was convicted of drug offenses and sentenced to a split term: three years in jail plus five years suspended with mandatory supervision.
- Mandatory supervision required court and probation officer consent before moving out of state.
- Wofford sought to transfer supervision to Virginia under the Interstate Compact; DA opposed, arguing ineligibility for mandatory supervision releasees.
- The trial court denied the request; Wofford sought a writ of mandate, which the appellate court granted, concluding mandatory supervision releasees may apply for Compact transfers.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether mandatory supervision releasees are eligible to apply for Compact transfers | Wofford: eligible under broad 'offender' and 'supervision' definitions | People: releasees under Realignment not eligible as they are inmates under supervision | Yes; mandatory supervision releasees are eligible to apply for transfers under the Compact |
Key Cases Cited
- Thornburg v. Superior Court, 138 Cal.App.4th 43 (Cal. Ct. App. 2006) (used to treat appeal as a writ on purely legal issue)
- People v. Cruz, 207 Cal.App.4th 664 (Cal. Ct. App. 2012) (Realignment context; discusses recidivism goals and community corrections)
- People v. Fandinola, 221 Cal.App.4th 1415 (Cal. Ct. App. 2013) (probation supervision nuances; supports broad eligibility concepts)
- In re L. Y. L., 101 Cal.App.4th 942 (Cal. Ct. App. 2002) (standing to challenge eligibility in Compact context)
- M.F. v. State of New York Executive Dept. Div. of Parole, 640 F.3d 491 (2d Cir. 2011) (federal authority: challenge to Compact eligibility; supports state-law issue)