Mar. 30, 2023 – People v. Cooks (4th Dist., Div. 1, D079706)

The Court of Appeal dismisses as unripe an appeal from trial counsel’s waiver of defendant’s right to be personally present at any future restitution hearing, where no restitution hearing has yet taken place. “[U]ntil a restitution hearing takes place in [defendant’s] absence, any error from an invalid waiver is hypothetical and not concrete.”