Does the doctrine of forfeiture apply to sentencing decisions where a defendant is ordered to serve a sentence that runs concurrently or consecutively?

California, United States of America


The following excerpt is from People v. Juarez, E059334 (Cal. App. 2014):

It is well established that a trial court has discretion to determine whether several sentences are to run concurrently or consecutively. ( 669; People v. Shaw (2004) 122 Cal.App.4th 453, 458.) A sentencing court is required to provide a statement of reasons when imposing consecutive sentences. (Cal. Rules of Court, rule 4.406(a), (b)(5).) Nevertheless, the forfeiture doctrine applies "to claims involving the trial court's failure to properly make or articulate its discretionary sentencing choices. Included in this category are cases in which the stated reasons allegedly do not apply to the particular

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