Does a new criminal conviction for a charge of possession of a drug with intent to commit a criminal offence violate subdivision (e) of the Criminal Code?

² We note the court sentenced defendant to a jail term of 545 days, a period of custody that exceeds his original felony sentence of 487 days (16 months). The parties do not address whether the new consecutive misdemeanor sentence violates subdivision (e) and, accordingly, we express no opinion on that potential issue.

Also, in his opening brief, defendant mentions in passing whether his days in PRCS should be credited to his parole period. However, he did not provide any reasoned argument or legal basis upon which to credit defendant these dayshis entire argument focuses on whether custody credits should apply to parole, an argument we resolved in his favor. Defendant's failure to develop his argument regarding alleged PRCS credits operates as a waiver of the issue on appeal. (Interinsurance Exchange v. Collins (1994) 30 Cal.App.4th 1445, 1448, 37 Cal.Rptr.2d 126 [parties are required to include argument and citation to authority in their briefs, and the absence of these necessary elements allows this court to treat appellant's ... issue as waived].)