Jun. 26, 2023 – People v. Codinha (4th Dist., Div. 1, D080633)

Disagreeing with People v. King (2022) 77 Cal.App.5th 629, the Court of Appeal holds that “a trial court’s inherent authority to correct an unauthorized sentence allows it to modify a final judgment in response to a notice from [CDCR] that a sentence does not contain a legally required component,” including by increasing the aggregate prison term. The court further holds that “the proper remedy [in this situation] is a full resentencing hearing where, as here, the sentence includes multiple components and the trial court exercised discretion at the original sentencing hearing to impose a nonmaximum aggregate prison term.”