People v. Parraorozco CA2/5

I. BACKGROUND

An information filed by the Los Angeles County District Attorney’s Office in 2018 charged defendant with one count of robbery in violation of Penal Code section 211.1 At a hearing in December 2018, the prosecution amended the information to add a second charge: assault likely to cause great bodily injury in violation of section 245, subdivision (a)(4). Defendant pled no contest to the assault charge and the trial court dismissed the robbery count. The trial court sentenced defendant to three years in prison, suspended execution of the sentence, and placed her on formal probation for three years. As we shall discuss in more detail, the Legislature subsequently enacted AB 1950, which amends section 1203.1 to limit the term of probation for most felonies to a maximum of two

1 Undesignated statutory references that follow are to the Penal Code.

2 years. (Stats. 2020, ch. 328, § 2.) AB 1950 took effect on January 1, 2021. On January 20, 2021, the prosecution moved to revoke defendant’s probation based on her violation of Vehicle Code section 10851, subdivision (a) (unlawfully taking a vehicle, which occurred a couple days earlier). At defendant’s probation violation…