result of a clerical error (California) · Go Syfert
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result of a clerical error in California

16 California opinions name it 2 courts 1941–2024 7 in the last five years

The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (6)

CaseFollowedCited
People v. Buycksgreen
· 2018 · cited in 2 California opinions naming this issue, 2023–2023
2 sentences

2023(See People v. Buycks (2018) 5 Cal.5th 857, 893 [“[W]hen part of a sentence is stricken on review, on remand for resentencing ‘a full resentencing as to all counts is appropriate, so the trial court can exercise its sentencing discretion in light of the changed circumstances.’ [Citations.]”].) DISPOSITION We do not foreclose the possibility that the absence of strike findings on the minute order and abstract of judgment is the result of a clerical error, and, if it can be clearly shown that the omission of those findings is result of a clerical error, the trial court may correct its judgment n

2023(See People v. Buycks (2018) 5 Cal.5th 857, 893 [“[W]hen part of a sentence is stricken on review, on remand for resentencing ‘a full resentencing as to all counts is appropriate, so the trial court can exercise its sentencing discretion in light of the changed circumstances.’ [Citations.]”].) DISPOSITION We do not foreclose the possibility that the absence of strike findings on the minute order and abstract of judgment is the result of a clerical error, and, if it can be clearly shown that the omission of those findings is result of a clerical error, the trial court may correct its judgment n

22
People v. Mesagreen
cal · 1975 · cited in 2 California opinions naming this issue, 2015–2023
2 sentences

2023“Any discrepancy between the judgment as orally pronounced and as recorded in the clerk’s minutes or abstract of judgment is presumed to be the result of clerical error” (People v. Leon (2020) 8 Cal.5th 831 , 855, citing People v. Mesa (1975) 14 Cal.3d 466, 471 ), and we may order correction on review (People v. Mitchell (2001) 26 Cal.4th 181, 185 , quoting In re Candelario (1970) 3 Cal.3d 702, 705 ).

2015Code, § 1213.5)[ ] it cannot add to or modify the judgment which it purports to digest or summarize.’ [Citation.]” (People v. Mesa (1975) 14 Cal.3d 466, 471 (Mesa).) On the record before us, we must presume that the discrepancy between the trial court’s oral pronouncement on July 17, 2014, and the July 18, 2014 corrected minute order and the abstract of judgment is the result of a clerical error.

12
Bowden v. Greengreen
calctapp · 1982 · cited in 1 California opinions naming this issue, 2020–2020
1 sentence

2020(See Bowden v. Green (1982) 128 Cal.App.3d 65, 71 [“A clerical error in a judgment is an inadvertent one made by the court which cannot reasonably be attributed to the exercise of judicial consideration or discretion.”].) Without opposition from Mrs. Turner, Mr. Turner requests that we vacate the judgment and remand for the trial court to correct the clerical error.

11
People v. Rowlandgreen
calctapp · 1988 · cited in 1 California opinions naming this issue, 2015–2015
1 sentence

2015(See Mesa, supra, 14 Cal.3d at pp. 471-472.) “[I]f the minutes or abstract of judgment fails to reflect the judgment pronounced by the court, the error is clerical and the record can be corrected at any time to make it reflect the true facts. [Citation.]” (People v. Little (1993) 19 Cal.App.4th 449, 452 ; see also People v. Rowland (1988) 206 Cal.App.3d 119, 123 [same].) Further, California Rules of Court, rule 8.155(c)(1) provides in part that “on its own motion, the reviewing court may order the correction . . . of any part of the record.” We will therefore order the clerk of the superior co

11
Wilson v. Wilsongreen
calctapp · 1948 · cited in 1 California opinions naming this issue, 1952–1952
2 sentences

1952If a clerical error, the court had power to supply the omission; otherwise, not. “ The test for determining whether a judicial error is a clerical one laid down by the Supreme Court in Estate of Goldberg, supra, 10 Cal.2d 709, 715 [ 76 P.2d 508 ], is whether the error is one ‘which cannot reasonably be attributed to exercise of judicial consideration or discretion.’ ” (Wilson v. Wilson, 88 Cal.App.2d 382, 384 [ 198 P.2d 916 ].) *675 Our examination of the record convinces us that the asserted omission was not the result of a clerical error.

1952If a clerical error, the court had power to supply the omission; otherwise, not. “ The test for determining whether a judicial error is a clerical one laid down by the Supreme Court in Estate of Goldberg, supra, 10 Cal.2d 709, 715 [ 76 P.2d 508 ], is whether the error is one ‘which cannot reasonably be attributed to exercise of judicial consideration or discretion.’ ” (Wilson v. Wilson, 88 Cal.App.2d 382, 384 [ 198 P.2d 916 ].) *675 Our examination of the record convinces us that the asserted omission was not the result of a clerical error.

11
Estate of Goldberggreen
cal · 1938 · cited in 1 California opinions naming this issue, 1952–1952
2 sentences

1952If a clerical error, the court had power to supply the omission; otherwise, not. “ The test for determining whether a judicial error is a clerical one laid down by the Supreme Court in Estate of Goldberg, supra, 10 Cal.2d 709, 715 [ 76 P.2d 508 ], is whether the error is one ‘which cannot reasonably be attributed to exercise of judicial consideration or discretion.’ ” (Wilson v. Wilson, 88 Cal.App.2d 382, 384 [ 198 P.2d 916 ].) *675 Our examination of the record convinces us that the asserted omission was not the result of a clerical error.

1952If a clerical error, the court had power to supply the omission; otherwise, not. “ The test for determining whether a judicial error is a clerical one laid down by the Supreme Court in Estate of Goldberg, supra, 10 Cal.2d 709, 715 [ 76 P.2d 508 ], is whether the error is one ‘which cannot reasonably be attributed to exercise of judicial consideration or discretion.’ ” (Wilson v. Wilson, 88 Cal.App.2d 382, 384 [ 198 P.2d 916 ].) *675 Our examination of the record convinces us that the asserted omission was not the result of a clerical error.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in California. Read the followed side critically anyway.

Also cited on this issue (16)

CaseCitedYears
Quinn v. City of Los Angeles green
calctapp · 2000
2 sentences

2023(Quinn, supra, 84 Cal.App.4th at p. 475 .) When his hearing impairment was discovered, his employment was terminated.

2013(Quinn, supra, 84 Cal.App.4th at p. 475 .) Quinn had failed the medical exam because of a significant hearing impairment, but as a result of a clerical error, he was notified to report for further tests.

22013–2023
In Re Candelario green
cal · 1970
2 sentences

2023“Any discrepancy between the judgment as orally pronounced and as recorded in the clerk’s minutes or abstract of judgment is presumed to be the result of clerical error” (People v. Leon (2020) 8 Cal.5th 831 , 855, citing People v. Mesa (1975) 14 Cal.3d 466, 471 ), and we may order correction on review (People v. Mitchell (2001) 26 Cal.4th 181, 185 , quoting In re Candelario (1970) 3 Cal.3d 702, 705 ).

2021“It is not open to question that a court has the inherent power to correct clerical errors in its records so as to make these records reflect the true facts.” (In re Candelario (1970) 3 Cal.3d 702, 705 .) Here, the true facts evidenced by the reporter’s transcript and agreed upon by the parties are that appellant declined to admit he violated probation, and the court found he did only after considering evidence and hearing argument from the parties.

22021–2023
People v. Cameron green
calctapp · 1994
2 sentences

2008(See Hansen , at p. 312 [discussing felony-murder cases involving assault with a deadly weapon as predicate, inherently dangerous felony]; People v. Rhodes (1989) 215 Cal.App.3d 470 , 476 fn. 2 [ 263 Cal.Rptr. 603 ], disapproved on another ground in People v. Barton, supra , 12 Cal.4th at p. 198 , fn. 7.) Garcia does not challenge this conclusion. 5 A Reporter's Note in People v. Cameron, supra , 30 Cal.App.4th at page 602 , footnote *, explains the decision in People v. Rhodes, supra , 215 Cal.App.3d 470 , remained published as the result of a clerical error.

2008A Reporter’s Note in People v. Cameron, supra, 30 Cal.App.4th at page 602 , footnote *, explains that the decision in People v. Rhodes, supra, 215 Cal.App.3d 470 , remained published as the result of a clerical error.

22008–2008
People v. Rhodes green
calctapp · 1989
2 sentences

2008(See Hansen , at p. 312 [discussing felony-murder cases involving assault with a deadly weapon as predicate, inherently dangerous felony]; People v. Rhodes (1989) 215 Cal.App.3d 470 , 476 fn. 2 [ 263 Cal.Rptr. 603 ], disapproved on another ground in People v. Barton, supra , 12 Cal.4th at p. 198 , fn. 7.) Garcia does not challenge this conclusion. 5 A Reporter's Note in People v. Cameron, supra , 30 Cal.App.4th at page 602 , footnote *, explains the decision in People v. Rhodes, supra , 215 Cal.App.3d 470 , remained published as the result of a clerical error.

2008(See Hansen , at p. 312 [discussing felony-murder cases involving assault with a deadly weapon as predicate, inherently dangerous felony]; People v. Rhodes (1989) 215 Cal.App.3d 470 , 476 fn. 2 [ 263 Cal.Rptr. 603 ], disapproved on another ground in People v. Barton, supra , 12 Cal.4th at p. 198 , fn. 7.) Garcia does not challenge this conclusion. 5 A Reporter's Note in People v. Cameron, supra , 30 Cal.App.4th at page 602 , footnote *, explains the decision in People v. Rhodes, supra , 215 Cal.App.3d 470 , remained published as the result of a clerical error.

22008–2008
People v. Ernst green
cal · 1994
1 sentence

2024Accordingly, defendant was deprived of his right to a jury trial.3 (See Ernst, supra, 8 Cal.4th at pp. 448–449.) DISPOSITION The judgment is reversed and the matter remanded for defendant to exercise his right to a jury trial. 3 As the judgment is reversed and remanded, we need not reach the second issue raised by defendant as to whether the court properly imposed and stayed a $300 probation revocation fine pursuant to section 1202.44. 5.

12024–2024
People v. Mitchell green
cal · 2001
1 sentence

2023“Any discrepancy between the judgment as orally pronounced and as recorded in the clerk’s minutes or abstract of judgment is presumed to be the result of clerical error” (People v. Leon (2020) 8 Cal.5th 831 , 855, citing People v. Mesa (1975) 14 Cal.3d 466, 471 ), and we may order correction on review (People v. Mitchell (2001) 26 Cal.4th 181, 185 , quoting In re Candelario (1970) 3 Cal.3d 702, 705 ).

12023–2023
Conservatorship of Tobias green
calctapp · 1989
1 sentence

2022(Hennefer v. Butcher (1986) 182 Cal.App.3d 492, 506 ; Conservatorship of Tobias (1989) 208 Cal.App.3d 1031, 1035 .) Because we conclude the claim for account stated is sufficient to sustain the judgment, it is unnecessary for us to discuss whether the judgment also could be sustained based on the other theories alleged in the complaint (open book account and quantum meruit).

12022–2022
Hennefer v. Butcher green
calctapp · 1986
1 sentence

2022(Hennefer v. Butcher (1986) 182 Cal.App.3d 492, 506 ; Conservatorship of Tobias (1989) 208 Cal.App.3d 1031, 1035 .) Because we conclude the claim for account stated is sufficient to sustain the judgment, it is unnecessary for us to discuss whether the judgment also could be sustained based on the other theories alleged in the complaint (open book account and quantum meruit).

12022–2022
Serrano v. Unruh green
cal · 1982
1 sentence

2016(See Christian Research Institute, supra, 165 Cal.App.4th at pp. 1321-1322, quoting Serrano v. Unruh, supra, 32 Cal.3d at p. 635 .) Because the court’s finding that the duplicative billing was the result of a clerical error was not “clearly wrong,” we find no abuse of discretion.

12016–2016
Christian Research Institute v. Alnor green
calctapp · 2008
1 sentence

2016(See Christian Research Institute, supra, 165 Cal.App.4th at pp. 1321-1322, quoting Serrano v. Unruh, supra, 32 Cal.3d at p. 635 .) Because the court’s finding that the duplicative billing was the result of a clerical error was not “clearly wrong,” we find no abuse of discretion.

12016–2016
Calvo Fisher & Jacob LLP v. Lujan green
calctapp · 2015
1 sentence

2016(See Calvo Fisher & Jacob, supra, 234 Cal.App.4th at p. 620 .)8 DISPOSITION The judgment is affirmed.

12016–2016
People v. Little green
calctapp · 1993
1 sentence

2015(See Mesa, supra, 14 Cal.3d at pp. 471-472.) “[I]f the minutes or abstract of judgment fails to reflect the judgment pronounced by the court, the error is clerical and the record can be corrected at any time to make it reflect the true facts. [Citation.]” (People v. Little (1993) 19 Cal.App.4th 449, 452 ; see also People v. Rowland (1988) 206 Cal.App.3d 119, 123 [same].) Further, California Rules of Court, rule 8.155(c)(1) provides in part that “on its own motion, the reviewing court may order the correction . . . of any part of the record.” We will therefore order the clerk of the superior co

12015–2015
People v. Hong green
calctapp · 1998
1 sentence

2015(People v. Hong (1998) 64 Cal.App.4th 1071, 1075 .) Here, the trial court orally pronounced a no visitation order under section 1202.05, which requires the sentencing court to prohibit visitation between a defendant convicted of certain sex offenses and his "child victim." Section 646.9, subdivision (k), on the other hand, provides that the sentencing court should consider issuing a restraining order against a defendant convicted of stalking.

12015–2015
People v. Delgado green
cal · 2008
1 sentence

2015(People v. Delgado (2008) 43 Cal.4th 1059, 1070 .) A discrepancy between the judgment as orally pronounced by the court and as entered in the minutes is presumably the result of a clerical error.

12015–2015
People v. Barton green
cal · 1995
1 sentence

2008(See Hansen , at p. 312 [discussing felony-murder cases involving assault with a deadly weapon as predicate, inherently dangerous felony]; People v. Rhodes (1989) 215 Cal.App.3d 470 , 476 fn. 2 [ 263 Cal.Rptr. 603 ], disapproved on another ground in People v. Barton, supra , 12 Cal.4th at p. 198 , fn. 7.) Garcia does not challenge this conclusion. 5 A Reporter's Note in People v. Cameron, supra , 30 Cal.App.4th at page 602 , footnote *, explains the decision in People v. Rhodes, supra , 215 Cal.App.3d 470 , remained published as the result of a clerical error.

12008–2008
Burnett v. Burnett green
cal · 1938
2 sentences

1941The recitals in an order of a trial judge that a judgment was signed by him as a result of a clerical error are not conclusive upon an appellate court (Estate of Burnett, 11 Cal. (2d) 259 [ 79 Pac. (2d) 89 ]; Stevens v. Superior Court, supra), and in the present case, the record is absolutely devoid of any evidence to support the statement that a clerical error was made.

1941The recitals in an order of a trial judge that a judgment was signed by him as a result of a clerical error are not conclusive upon an appellate court (Estate of Burnett, 11 Cal.2d 259 [79 PaCal.2d 89]; Stevens v. Superior Court, supra), and in the present case, the record is absolutely devoid of any evidence to support the statement that a clerical error was made.

11941–1941

Where else courts name it

CA 16 (1941–2024) TX 13 (1955–2013) NY 7 (1999–2018) NC 4 (2009–2014) IL 3 (1983–2010) MO 3 (1889–2003) WA 3 (1978–1996) OH 3 (2009–2017) GA 2 (1902–1927) NJ 2 (2005–2005) AZ 2 (2005–2005) MI 2 (1979–2014) NE 2 (1984–1998) IN 2 (2000–2000) MA 2 (2011–2011)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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