California v. Carrea
Annotate this CaseChristopher Carrea appealed the denial of his Penal Code section 1170.18 motion to dismiss a one-year prison prior enhancement, imposed at his 2013 sentencing for conviction of inflicting corporal injury to a former cohabitant. He argued that because, after his sentencing, he obtained a section 1170.18 order reducing the 2004 convictions on which that prison prior enhancement was based from felonies to misdemeanors, the trial court should have stricken or dismissed that enhancement pursuant to section 1170.18 and Proposition 47. Because the Court of Appeal concluded section 1170.18 did not provide for retroactive redesignation, dismissal, or striking of final pre-Proposition 47 sentence enhancements based on prior convictions that were subsequently reduced from felonies to misdemeanors pursuant to section 1170.18, the court correctly denied his motion.
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