Brown

*1174 In accordance with a plea bargain, defendant Karen Renee Brown pleaded guilty to one count of receiving stolen property in violation of Penal Code 1 section 496, subdivision (a). The People dismissed two additional felony counts of receiving stolen property in violation of section 496, subdivision (a), and dismissed three felony counts of identity theft in violation of section 530.5, subdivision (a). The plea agreement anticipated defendant would serve two years in county jail. The trial court accepted defendant's plea and sentenced her to two years in county jail as recommended by the People. Shortly thereafter, the voters approved Proposition 47, the Safe Neighborhoods and Schools Act, which reduced certain property and drug offenses from felonies to misdemeanors and provides for resentencing of certain defendants currently serving felony sentences under prior law. Defendant promptly petitioned the trial court for resentencing. The trial court granted defendant's petition and resentenced her to 364 days in county jail.

In this appeal, the People contend the trial court erred by granting defendant's petition. According to the People, Proposition 47 should not be…