Aguirre

Defendant Beatrice Aguirre was detained by store security personnel after attempting to pay for purchases with a suspected counterfeit $100 bill. She was placed under arrest by a responding police officer, who, on conducting a search of defendant's purse incident to her arrest, found $1,130 in counterfeit $100, $20 and $5 bills, as well as 40 "washed out" $1 bills the officer believed were on their way to becoming counterfeit $100 bills. Defendant was charged with several felonies, including one count of forgery in violation of Penal Code section 476. She subsequently pleaded no contest to the forgery charge. The following year, defendant sought to recall her sentence under Proposition 47 ( Cal. Const., art. II, § 10, subd. (a); Pen. Code, § 1170.18 ) for resentencing as a misdemeanor. The trial court denied her petition on the ground the value of the counterfeit currency exceeded $950.

Defendant's principal argument on appeal is that the trial court erred in totaling the value of the counterfeit currency she *329 possessed and should have, *431 instead, followed cases holding the face amounts of forged checks cannot be aggregated for purposes of Proposition 47. We conclude the…