Does the trial court have a discretionary decision to prohibit reference to another trial involving different facts?

The trial court's discretionary decision to prohibit reference to another trial involving different facts was not erroneous as a matter of law. In People v. Mendoza (1974) 37 Cal.App.3d 717, 112 Cal.Rptr. 565, the defendant's attorney wished to read substantially similar newspaper articles to the jury. The court concluded that summation must be based upon the evidence in the case. "Counsel may refer the jury to ... common experience, history, or literature [citation], but he may not dwell on the particular facts of unrelated, unsubstantiated cases.... [T]he court properly denied defense counsel license to read newspaper clippings about unrelated specific crimes, hearsay material which could only confuse the jury with irrelevant facts." (Id., at p. 725, 112 Cal.Rptr. 565.)

The People contend that elements of the trial court's 18-year sentence were unauthorized and should be corrected. We agree. Although the People did not file a notice of appeal, an unauthorized sentence may be corrected at any time. (People v. Dotson (1997) 16 Cal.4th 547, 554, fn. 6, 66 Cal.Rptr.2d 423,

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