People v. Espinoza, 232 Cal.App.4th Supp. 1 (Dec. 2, 2014) (trial court lacks authority to dismiss an action under Penal Code 1385 after probation has expired).

Note: This decision was rendered by the Appellate Division of the Fresno County Superior Court, and arguably has no statewide application. The decision is arguably incorrect, since it violates the California Supreme Courts holding in other cases that courts cannot construct limitations on the scope of Penal Code 1385 that were not expressly enacted by the Legislature. Here, the Legislature never provided that the trial courts power to grant a 1385 dismissal ends when probation is terminated. In People v. Williams (1981) 30 Cal.3d 470, 482, the Supreme Court stated: Section 1385 permits dismissals in the interests of justice in any situation where the Legislature has not clearly evidenced a contrary intent. A request for depublication is contemplated.
Cal Crim Def 20.35