Abdullah

In 2002, defendant and appellant Warith Deen Abdullah was convicted of 13 counts of armed robbery and one count of assault with a deadly weapon, and sentenced to over 40 years in prison. The sentence included firearm enhancements under Penal Code section 12022.53 1 that were mandatory at the time of the sentencing. Fifteen years later, the Department of Corrections and Rehabilitation (DCR) sent a letter to the trial court calling attention to errors in Abdullah's abstract of judgment. Before the trial court, Abdullah argued that the court must hold a new hearing to sentence him "in the same manner as if he ... had not previously been sentenced" (§ 1170, subd. (d)(1)), and that he is entitled to the benefit of changes in the law that came into effect after his original sentencing. Specifically, Abdullah contended that the court must exercise its discretion whether to strike his firearm enhancements pursuant to recently enacted Senate Bill No. 620 (2017-2018 Reg. Sess.) (Stats. 2017, ch. 682, pp. 5104-5106) (Senate Bill No. 620). The trial court refused to consider striking the enhancements and instead simply corrected the errors in the abstract of judgment without altering the…