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P. v. Foots
Defendant Michael Foots appeals from a judgment sentencing him to a four-year prison term following revocation of probation. He contends that the trial court erred in sentencing him without benefit of a supplemental probation report, instead relying on a report prepared over two years earlier when he was granted probation. The People concede the trial courts error but contend defendant has not demonstrated he was prejudiced by the error. Court reverse.

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