Jul. 6, 2023 – People v. Jackson (1st Dist., Div. 4, A164649)

Agreeing with People v. Canedos (2022) 77 Cal.App.5th 469 (and disagreeing with People v. Faial (2022) 75 Cal.App.5th 738), the Court of Appeal holds that where a defendant was found to have committed a probation violation more than two years after being placed on probation, but before AB 1950 took effect, AB 1950’s amendments to PC 1203.1 apply retroactively to terminate the defendant’s probation prior to the violation. The court reverses the order revoking and terminating defendant’s probation.

Note: This issue is currently pending in the California Supreme Court in People v. Faial (S273840).