California, United States of America
The following excerpt is from People v. Coelho, C071535 (Cal. App. 2015):
Nevertheless, since the oral pronouncement constitutes the judgment and controls over conflicting writings (People v. Mitchell (2001) 26 Cal.4th 181, 185-187; People v. Scott (2012) 203 Cal.App.4th 1303, 1324), we modify the judgment to correct the mistaken citation to subdivision (e) and to provide for a restitution fine under subdivision (b) of section 1202.4, as correctly indicated in the minutes and abstract of judgment.
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