People v. Bouchafra CA1/1

I.

FACTUAL AND PROCEDURAL

BACKGROUND

In September 2013, Bouchafra pleaded guilty to one count of battery on a person with whom he was in a dating relationship and two counts of annoying phone calls, all misdemeanors.2 We do not discuss the facts supporting these convictions because they are not relevant to the issues on appeal. The trial court sentenced Bouchafra to a total term of one year, 364 days in county jail, comprised of a term of 364 days for the battery and consecutive sentences of six months each for the annoying phone calls. The court suspended execution of the sentence and placed Bouchafra on formal probation for three years. His probation conditions included a warrantless search condition, an order to stay away from his ex- girlfriend, and a requirement that he “comply with all the terms and conditions of the Adult Probation Department’s individualized treatment and rehabilitation plan.”3 No travel-authorization requirement was included in either the written or oral probation conditions, but on multiple occasions the trial court told Bouchafra not to travel outside the state without permission. The first time was in connection with a probation violation. He…