California, United States of America
The following excerpt is from People v. Rogers, G052346 (Cal. App. 2016):
Appellate counsel went the extra mile and considered an argument that since appellant was no longer on probation at the time of the restitution hearing (it had been continued several times), the court had no jurisdiction to decide restitution. But this issue has been resolved against appellant in People v. Ford (2015) 61 Cal.4th 282, on remarkably similar facts.
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