California Supreme Court

In re G.C.

February 20, 2020

Summary

The court held that G.C. could not challenge the juvenile court’s failure to declare her wobbler offenses misdemeanors or felonies in an appeal from a later section 777 dispositional order. The original dispositional order was final because G.C. did not timely appeal it, and section 702 imposed no continuing duty requiring the later court to revisit the prior omission. The failure to make the declaration was not an unauthorized sentence correctable despite the untimely appeal, so the Court of Appeal properly dismissed the appeal.