Can a probation officer's report include this circumstance?

every circumstance on the record. The court stated it had considered the probation officer's report, which included this circumstance and attached the letter. "'A trial court may minimize or even entirely disregard mitigating factors without stating its reasons.' [Citation.] Further, unless the record affirmatively reflects otherwise, the trial court will be deemed to have considered the relevant criteria, such as mitigating circumstances, enumerated in the sentencing rules. [Citation.]" (People v. Zamora (1991) 230 Cal.App.3d 1627, 1637.)

Defendant also argues that the court relied heavily on the fact that she was able to get drugs into prison, a fact that was very similar to the possession element of her crime and therefore could not be used to deny probation (People v. Parrott (1986) 179 Cal.App.3d 1119, 1125 ["If such a fact cannot be used to impose the upper term if it is an element of the crime, it should not be used to deny probation."]). We disagree with this analysis. The trial court did not rely on the fact that defendant possessed the drugs. It discussed her execution of a complex plan that, naturally, included possession of the drugs.