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P. v. Koski
Steven Allen Koski was charged with one count of grand theft of personal property and ten counts of burglary. Koski pleaded guilty to grand theft and the remaining burglary charges were dismissed. The plea agreement specified that any time served would be concurrent with a separate case against Koski and that the sentence would "stipulate to 3 years local prison." Koski moved for an alternative or "split" sentence under the Criminal Justice Realignment Act of 2011. (Stats. 2011, 1st Ex. Sess. 2011–2012, ch. 15, § 1.) After reviewing the change of plea form, the trial court denied the motion finding the parties had stipulated to a three-year prison commitment. It noted, however, that even if it had the discretion to impose a split sentence, it would decline to do so because Koski's criminal history revealed he was not an appropriate candidate for probation monitoring. Specifically, the court noted that the matter involved two separate cases, Koski had been to prison at least once before and the cases involved great monetary loss to the victims.
The court sentenced Koski to three years in county jail, concurrent with his other case. The trial court imposed several fines and fees and gave Koski credit for time served.

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