Is the record of conviction sufficient to support a motion to resent a sentence under the Criminal Proceeds of Crime Act?

Hudson asserts Sherow, supra, 239 Cal.App.4th 875 was wrongly decided as it suggests that the trial court is empowered to look beyond the record of conviction in determining whether a petitioner's offense qualifies for relief under the Act. To the extent Hudson contends a petitioner under the Act is limited to the record of conviction to prove sentencing eligibility this argument works against him in situations where, as here, the record is silent. (People v. Perkins (2016) 244 Cal.App.4th 129, 140, fn. 5 [in many cases, "the value of the property was not important at the time of conviction, so the record may not contain sufficient evidence to determine its value"; petitioners may seek

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to meet their burden on this issue by "submit[ting] extra-record evidence probative of the value when they file their petitions for resentencing"].) Sherow does not address a situation where the People went outside the record of conviction to prove resentencing eligibility. (People v. Alvarez (2002) 27 Cal.4th 1161, 1176 ["[I]t is axiomatic that cases are not authority for propositions not considered."].)