People v. Catalan CA4/3

Marvin Estuardo Catalan pleaded guilty to four felonies, including grand theft (Pen. Code, § 487, subd. (a); all statutory references are to the Penal Code unless noted), identity theft (§ 530.5, subd. (a)), and two counts of forgery (§ 470, subd. (d)). The court imposed a four-year hybrid or split sentence (§ 1170, subd. (h)) comprised of a one-year four-month jail term followed by two years eight months of mandatory supervision on specified terms and conditions. After Catalan violated the terms of his mandatory supervision, the trial court revoked and reinstated his supervision and added 550 days to his jail sentence. Catalan contends the court abused its discretion by imposing a sentence exceeding the recommended term under the Criminal Justice Realignment Act of 2011 (Realignment Act), operative October 1, 2011. (Stats. 2011, 1st Ex. Sess. 2011-2012, ch. 12, § 1; see, e.g., § 1230, subd. (b)(3).) For the reasons expressed below, we affirm.

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Facts and Procedural Background

In April 2012, Catalan pleaded guilty to four felonies, including grand theft, identity theft, and forgery. The prosecutor agreed to dismiss 15 similar counts involving additional victims.…