People v. Oden CA2/5

California Court of Appeal Mar 20, 2026 No. B341857Unpublished

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Holding. The court held that it lacked jurisdiction to entertain an appeal from the denial of a motion to recalculate custody credits because the trial court lacked jurisdiction to entertain the underlying motion after the defendant's conviction became final.

Issues

Whether a trial court has jurisdiction to rule on a freestanding motion to recalculate presentence custody credits after a conviction is final.
Whether the appellate court has jurisdiction to entertain an appeal from the denial of a motion over which the trial court lacked jurisdiction.

Disposition. Dismissed.

Quotations verified verbatim against the opinion

“Where the trial court lacks jurisdiction to entertain a motion, this Court lacks jurisdiction to entertain an appeal from the denial of that motion.”

“we believe the best course is to follow our Supreme Court’s most recent word on the matter in In re G.C. and hold the trial court accordingly lacked jurisdiction to entertain defendant’s motion.”

Filed 3/20/26 P. v. Oden CA2/5 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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 FIVE

THE PEOPLE, B341857

Plaintiff and Respondent, (Los Angeles County Super. Ct. No. v. NA048461)

TERRELL ODEN,

Defendant and Appellant.

APPEAL from an order of the Superior Court of Los Angeles County, Laura L. Laesecke, Judge. Dismissed. Micah Reyner, 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, Senior Assistant Attorney General, Idan Ivri, Supervising Deputy Attorney General, Marc A. Kohm, Deputy Attorney General, for Plaintiff and Respondent.

Defendant Terrell Oden (defendant) was convicted of first degree murder and conspiracy to commit murder more than 20 years ago. In 2006, on appeal from the judgment, this Court reversed a sentencing enhancement and remanded for the trial court to make specified amendments to the abstract of judgment. Later, in 2024, defendant filed a freestanding “Motion for an Order Awarding Additional Custody Credits” that argued the trial court should recalculate his presentence custody credits. The trial court denied that motion and we consider whether we have jurisdiction to entertain this appeal from that ruling when the trial court had no jurisdiction to decide the motion in the first place.

I. BACKGROUND A. Conviction and Sentencing1 Defendant was charged with three counts of murder, one count of conspiracy to commit murder, and two counts of attempted murder. As to all but the conspiracy count, it was alleged the crimes were committed for the benefit of a criminal street gang (Pen. Code, § 186.22, subd. (b)) and a principal used a firearm in the commission of the offense (Pen. Code, § 12022.53, subds. (b), (e)(1)).2 Following an initial mistrial where the jury was deadlocked, the jury at defendant’s second trial found him guilty

People v. Oden CA2/5

AI Brief

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION FIVE

THE PEOPLE, B341857

TERRELL ODEN,

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NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS

BAKER, J.

HOFFSTADT, P. J.

MOOR, J.

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