People v. Guerrero

Summary

The court held that the identity-theft exception to Proposition 47's misdemeanor reduction for forgery applies only when the forgery and identity theft were committed in the same proceeding and one offense facilitated the other. Merely possessing stolen identification and a forged instrument at the same time and place, without evidence of a facilitative relationship, is insufficient. Because no evidence connected Guerrero's stolen identification to his counterfeit bill and the bill was worth less than $950, the court reversed and directed reduction of the forgery conviction to a misdemeanor.