In what circumstances will a judge overturn a sentence based on a probation report that lists 10 prior arrests?

[98 Cal.App.3d 164] In People v. Phillips (1977) 76 Cal.App.3d 207, 142 Cal.Rptr. 658, the probation report listed 10 arrests with indications of either "no disposition shown" or "dismissed for

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In People v. Jackson (1978) 78 Cal.App.3d 533, 144 Cal.Rptr. 199, the appellant complained that the trial judge had improperly relied in sentencing upon statements in a probation officer's report concerning prior police contacts not verified with supporting factual information. Acknowledging that "without supporting factual information and a proper concern for reliability police contacts not leading to arrest or conviction may not be relied upon" (id., at 539, 144 Cal.Rptr. at 203), and that the probation report contained some such data, the court declined to overturn the sentence in the absence of evidence "that any factually unsubstantiated police contacts contained in the probation officer's report actually misled the judge." (Id., at 541, 144 Cal.Rptr. at 204.)