Does the doctrine of forfeiture apply to a defendant's failure to challenge the imposition of a probation supervision fee and the cost of preparing a probation report?

California, United States of America


The following excerpt is from People v. Rodriguez, E057406 (Cal. App. 2014):

However, the inclusion of procedural safeguards does not compel the conclusion that forfeiture does not apply. Forfeiture principles have been applied to a defendant's failure to challenge the imposition of the cost of preparing the probation report and the imposition of a probation supervision fee, pursuant to section 1203.1. (People v. Snow (2013) 219 Cal.App.4th 1148, 1151.) Section 1203.1b, governing orders for probation

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