California v. Phoenix
Annotate this CaseDefendant Ronald Phoenix was convicted of crimes in Sacramento and Yolo Counties. He was originally sentenced to prison in the Sacramento County case. The Yolo County trial court resentenced defendant on the Sacramento case and consolidated the sentences as required by Penal Code sections 669 and 1170.1, and the California Rules of Court. Defendant’s sole contention on appeal was that the Yolo County trial court erred when it refused to calculate custody credits in the Sacramento case for the time he spent in custody before he was sentenced on the Yolo County case. The State argued Sacramento County should make the calculation. The Court of Appeal reversed and remanded the case to Yolo County for recalculation of defendant’s credits on both the Sacramento County and Yolo County cases.
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