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P. v. Madrigal CA4/2
In this Proposition 47 case, defendant Randy Joe Madrigal appeals an order denying his application for reduction of his felony conviction for receiving a stolen vehicle (Pen. Code, § 496d, subd. (a) ) to a misdemeanor (application for reduction). Defendant contends Proposition 47 (§ 1170.18) implicitly includes a section 496d felony because the crime qualifies for reduction under section 496, subdivision (a), which makes receipt of stolen property valued at $950 or less a misdemeanor.

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