Error and/or relief
Where the sentence is life without the possibility of parole, it was improper to impose a parole revocation fine, and it must be stricken.
Holding:
A parole revocation fine may not be imposed for a term of LWOP, as the statute is expressly inapplicable where there is no period of parole. Moreover, our Supreme Court recently recognized that the parole revocation fine statute does not apply where a defendant is given both an LWOP sentence and an indeterminate term.
Authority:
PEN 1202.45
People v. Jenkins (2006) 140 Cal.App.4th 805, 819
People v. Alvarez (2025) 18 Cal.5th 387, 485–486