California Supreme Court

The People, Plaintiff and Respondent v. Ruben Phillip Franco, Defendant and Appellant.

December 10, 2018240 Cal. Rptr. 3d 766

Summary

The court held that, for purposes of Proposition 47's misdemeanor threshold, the value of a forged check containing a stated amount is the amount written on the check. Because the defendant's forged check was made out for $1,500, it exceeded the $950 threshold and remained punishable as a felony. The court affirmed the Court of Appeal and rejected the intrinsic-paper-value and actual-market-worth approaches.