People v. Phillips CA2/4

California Court of Appeal Mar 19, 2026 No. B339154Unpublished

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Holding. The court held that the trial court lacked jurisdiction to revoke the defendant's probation because the probation term had already expired by operation of law under the retroactive application of amended Penal Code section 1203.1.

Issues

Whether the amended probation term limits of Penal Code section 1203.1 apply retroactively to the defendant's existing probation term.
Whether the trial court retained jurisdiction to revoke probation after the expiration of the maximum term authorized by amended section 1203.1.

Disposition. Reversed and remanded

Quotations verified verbatim against the opinion

“appellant’s probation ended by operation of law on May 3, 2022, three years after it was imposed, and nearly two years before the trial court revoked it.”

“The court’s June 3, 2024 order terminating appellant’s probation and ordering execution of the suspended sentence was therefore erroneous.”

Filed 3/19/26 P. v. Phillips CA2/4 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS

California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION FOUR

THE PEOPLE, B339154

Plaintiff and Respondent, (Los Angeles County Super. Ct. No. MA075295) v.

CAMERON PHILLIPS,

Defendant and Appellant.

APPEAL from an order of the Superior Court of Los Angeles County, Lisa Strassner, Judge. Reversed and remanded. Law Office of Brad Poore and Brad J. Poore under appointment by the Court of Appeal, for Defendant and Appellant. Rob Bonta, Attorney General, Charles C. Ragland, Chief Assistant Attorney General, Susan Sullivan Pithey, Assistant

Attorney General, Noah P. Hill and Steven E. Mercer, Deputy Attorneys General, for Plaintiff and Respondent.

MEMORANDUM OPINION1 On April 12, 2019, appellant Cameron Phillips pled no contest to one count of driving under the influence of an alcoholic beverage and causing bodily injury. (Veh. Code, § 23153, subd. (a).) On May 3, 2019, the trial court imposed a stipulated midterm sentence of two years, suspended execution of the sentence, and placed appellant on five years of probation. On April 18, 2024, the court revoked appellant’s probation pending a probation violation hearing. After that contested hearing on June 3, 2024, the trial court found appellant in violation of his probation conditions, terminated probation, and imposed the previously suspended two-year sentence. Appellant timely appealed. While appellant was serving his five-year term of probation, the Legislature amended the statute governing probation, section 1203.1. The previous version of the statute allowed the trial court to grant probation “for a period of time not exceeding the maximum term for which the person could be imprisoned,” or “‘not over five years’” for an offense with a

People v. Phillips CA2/4

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IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION FOUR

THE PEOPLE, B339154

CAMERON PHILLIPS,

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