California v. Catalan
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Marvin Estuardo Catalan pleaded guilty to four felonies, including grand theft, identity theft, and two counts of forgery. The court imposed a four-year hybrid or split sentence comprised of a one-year, four-month jail term followed by two years and eight months of mandatory supervision on specified terms and conditions. After Catalan violated the terms of his mandatory supervision, the trial court revoked and reinstated his supervision and added 550 days to his jail sentence. Catalan argued on appeal the trial court abused its discretion by imposing a sentence exceeding the recommended term under the Criminal Justice Realignment Act of 2011. Finding no reversible error, the Court of Appeal affirmed.
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