P. v. Reed CA1/4
A jury found defendant Michael D. Reed guilty of possession of a firearm by a felon (Pen. Code, § 29800, subd. (a)(1)), together with true findings on various sentencing enhancements. He received an aggregate sentence of seven years in prison, which included one year for a prior prison term. On appeal, he argues (1) the trial court erred by failing to declare a mistrial on grounds of juror misconduct, (2) the one-year component of his sentence for a prior prison term must be stricken in light of the recent enactment of Senate Bill No. 136 (2019–2020 Reg. Sess.) (Stats. 2019, ch. 590, § 1), which he contends applies retroactively to nonfinal cases on appeal, and (3) the abstract of judgment erroneously states that he is entitled to 1376 days of custody credits, which he contends conflicts with the court’s oral pronouncement of sentence awarding him 1378 days of custody credits.
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