People v. Coddington
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In 2016, Coddington was charged with assault by force likely to cause great bodily injury and making a criminal threat, with special allegations of great bodily injury and allegations: that Coddington previously had been convicted of a serious felony, had a prior strike conviction, and had served three prior prison terms. Coddington pleaded guilty to the assault with the special allegation of great bodily injury, admitting the allegations, including one prison prior. The court sentenced Coddington to 13 years: the lower term of two years for the assault, doubled because of the prior strike, plus three years for great bodily injury, plus five years for the serious felony allegation, plus one year for the prison prior.
In 2022, Coddington moved to be resentenced, based on the intervening elimination of sentence enhancements for prison priors unless the prior term was for a sexually violent offense, Penal Code 1172.75(a). The court reduced Coddington’s sentence to 12 years, the entire relief Coddington had requested. On appeal, Coddington first argued that he was entitled to further reductions under Senate Bill 1393, giving courts discretion to dismiss or strike a prior serious felony allegation, and Senate Bill 81, which specifies factors that the court must consider when deciding whether to strike enhancements. The court of appeal remanded for a full resentencing, noting that if the court indicates that it will further reduce Coddington’s sentence, the prosecution may withdraw its assent to the plea agreement.
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