California, United States of America
The following excerpt is from People v. Fattal, C083067 (Cal. App. 2018):
3. We decline defendant's invitation to adopt the "reasonable possibility" standard articulated in People v. May (1990) 221 Cal.App.3d 836, 839. (See People v. Sanchez (1994) 23 Cal.App.4th 1680, 1685 [declining to adopt May standard]; People v. Davis, supra, 10 Cal.4th at p. 552 ["It is not reasonably probable that a more favorable sentence would have been imposed" absent the failure to articulate reasons for imposing consecutive sentences].)
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