P.

BACKGROUND

In April 2012, appellant was charged by felony complaint in case No. SCUKCRCR 12-21365 (Case No. 1) with six counts arising out of an incident in which

1 appellant drove a car without permission of its owner and while under the influence of drugs and/or alcohol. In May, appellant entered a plea of no contest to an unauthorized driving of a motor vehicle charge and a driving while under the influence of drugs and/or alcohol charge, after being advised of and thereafter waiving his constitutional rights. The prosecution agreed not to seek a state prison sentence if appellant entered and successfully completed a substance abuse treatment program. The trial court directed appellant to enter a residential treatment program, and the remaining counts were dismissed. In August 2012, appellant was charged by information in case No. SCUKCRCR 12-22837 (Case No. 2) with three counts of issuing checks with insufficient funds (Pen. Code, § 476a, subd. (a)). It was alleged that appellant committed the charges while out of custody on his own recognizance (id., § 12022.1) and that appellant had previously been convicted of a serious felony (id., §§ 667, 1170.12.) Appellant pled no…