People v. Huff CA1/5

CourtCalifornia Court of Appeal
DecidedSeptember 12, 2022
DocketA163958
StatusUnpublished

This text of People v. Huff CA1/5 (People v. Huff CA1/5) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Huff CA1/5, (Cal. Ct. App. 2022).

Opinion

Filed 9/12/22 P. v. Huff CA1/5

NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for pur- poses of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION FIVE

THE PEOPLE, Plaintiff and Respondent, v. A163958 ANTHONY QUINN HUFF, JR., Defendant and Appellant. (Napa County Super. Ct. No. 18CR001828)

Antony Quinn Huff, Jr., appeals after the trial court found a probation violation and imposed a two-year prison sentence. He asserts the violation occurred after his probation ended on January 1, 2021, by operation of new legislation that retroactively shortened the maximum probation term to two years. (Assem. Bill No. 1950 (2019-2020 Reg. Sess.), Stats. 2020, ch. 328, § 2, eff. Jan. 1, 2021 (AB 1950).) The People disagree. They suggest Huff had not served two years on probation as of January 1 because his term was tolled for roughly seven months following its summary revocation. More clearly, they contend Huff is estopped from denying the tolling because he agreed to it as part of a negotiated plea before the new legislation was enacted.

Their arguments miss their mark. First, Huff’s probation was never summarily revoked and, even if it had been, the tolling 1 triggered by summary revocation does not keep the probationary term from running. (People v. Leiva (2013) 56 Cal.4th 498 (Leiva); Pen. Code, § 1203.2, subd. (a).1) Second, Huff’s agreement to extend his probation by seven months does not estop him from invoking the benefit offered by AB 1950. We reverse.

BACKGROUND

A.

Probation revocation involves two steps. First, a court may summarily revoke probation when presented with reason to believe the probationer has violated its terms and conditions. Second, the defendant is thereafter entitled to a formal hearing at which the prosecution must prove the alleged violation. (§ 1203.2, subds. (b), (c), (e); Leiva, supra, 56 Cal.4th at pp. 505- 506, 516; People v. Braud (2020) 56 Cal.App.5th 962, 965-966 (Braud).) The summary revocation “shall serve to toll the running of the period of supervision.” (§ 1203.2, subd. (a).)

“Toll” has an unusual meaning in this context. Although the term is generally defined as to stop the running of a time period (Leiva, supra, 56 Cal.4th at pp. 508-509), the Supreme Court has rejected that definition for purposes of section 1203.2, subdivision (a). (Id. at pp. 507, 517-518.) Rather than suspend the probationary term upon summary revocation, “tolling” under this provision serves only to preserve the court’s jurisdiction to adjudicate an alleged violation that occurred during the probation term in a formal violation hearing held after its expiration. (Id. at p. 502; People v. Sem (2014) 229 Cal.App.4th 1176, 1192 (Sem) [tolling after summary revocation “is not a mechanism for extending [the] probationary period beyond its statutory time limits”].) While the court may choose to reinstate and extend the term of probation if it finds a violation, the tolling

1 Undesignated statutory citations are to the Penal Code. 2 does not automatically extend it so as to authorize a finding that probation was violated by acts committed after the original term. (Braud, supra, 56 Cal.App.5th at pp. 968-969; People v. Johnson (2018) 29 Cal.App.5th 1041, 1050.)

B.

On December 20, 2018, Huff was placed on three years of probation after he pled no contest to felony evading an officer (Veh. Code, § 2800.2, subd. (a).) Thirteen months later, on January 27, 2020, the probation department petitioned to revoke his probation for failures to report and obey his probation officer’s orders. The court issued a no-bail bench warrant the same day but, apparently due to an oversight, did not summarily revoke probation.

The probation revocation hearing was held almost eight months later, on September 11, 2020. Defense counsel acknowledged Huff had “dropped out of reporting with probation” and proposed his client would admit the violation and “agree to the tolling time of what looks to be . . . a little bit less than eight months.”

The court stated, “I’m going to release him from custody today in the underlying case; however, if he wants to resolve it right now, it would be revoke and reinstate, and toll probation.” Defense counsel explained to Huff that this would “extend[] the termination date by the seven months that you weren’t reporting to Napa.” Huff agreed to the proposal. After accepting his admission, the court stated, “[p]robation is revoked and reinstated. Your grant of probation is reinstated to include toll time while your probation was in revoked status. Your new expiration date is July 20th, 2022.”

Several months later, the maximum probation term for many felonies, including Huff’s, was reduced by statute to two years (§ 1203.1, former subd. (a), as amended by AB 1950).

3 Appellate courts have unanimously concluded that AB 1950 applies retroactively to cases that are not yet final. (People v. Arreguin (2022) 79 Cal.App.5th 787, 794 ; Kuhnel v. Appellate Division of Superior Court (2022) 75 Cal.App.5th 726, 729 , review granted June 1, 2022, S274000.)

On January 29, 2021, the court summarily revoked Huff’s probation after a January 9 arrest in Solano County. Huff petitioned to deem his probation terminated pursuant to AB 1950 as of January 1, 2021, the bill’s effective date and just over two years after he was placed on probation.

The People opposed the petition. They argued Huff had not been on probation for two years as of January 2021 because his term was tolled between January 27, 2020, when the first revocation petition was filed and the bench warrant issued, and the September 11, 2020 revocation hearing. Huff’s attorney disagreed, observing there was no legal basis to assert tolling because Huff’s probation had not been summarily revoked. Without tolling, Huff had been on probation for two years as of December 20, 2020, and was entitled to the benefit of AB 1950. Moreover, his agreement at the revocation hearing to extend probation by seven months did not change that result. “[P]robation was extended, but that’s not the same as tolling.”

After reviewing a transcript of the September 2020 hearing, the court ruled Huff was estopped from denying probation had been tolled because the parties “operated with the specific language of tolling” at the hearing, and Huff received a benefit from their agreement. The court revoked probation and sentenced Huff to two years in prison.

4 DISCUSSION

Although their position is premised on the concept of tolling under section 1203.2, subdivision (a), the People do not seriously contend Huff’s probation was summarily revoked so as to trigger tolling under that provision. Their forbearance is apt: the court left the summary revocation box unchecked on the January 27, 2020 order and later, when the oversight was discovered, declined to correct it nunc pro tunc. Their argument, rather, is that Huff’s September 2020 agreement to tolling estops him from asserting probation was not tolled.

But estoppel, if applied here, does not change the outcome. As we have explained, tolling in the context of the probation revocation process does not keep the probationary clock from ticking. (Leiva, supra, 56 Cal.4th at pp. 502, 507-518; Sem, supra, 229 Cal.App.4th at p. 1192; Braud, supra, 56 Cal.App.5th at pp. 968-979.) With or without tolling, then, Huff’s probationary term continued to run after January 27, 2020, with the result that he had been on probation for more than two years when AB 1950 took effect on January 1, 2021.

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Related

People v. Leiva
297 P.3d 870 (California Supreme Court, 2013)
Doe v. Harris
302 P.3d 598 (California Supreme Court, 2013)
Way v. Superior Court of San Diego Cty.
74 Cal. App. 3d 165 (California Court of Appeal, 1977)
People v. Jackson
36 Cal. Rptr. 3d 477 (California Court of Appeal, 2005)
People v. Heng Sem
229 Cal. App. 4th 1176 (California Court of Appeal, 2014)
In re Griffin
431 P.2d 625 (California Supreme Court, 1967)
People v. Johnson
240 Cal. Rptr. 3d 855 (California Court of Appeals, 5th District, 2018)

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People v. Huff CA1/5, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-huff-ca15-calctapp-2022.