People v. The North River Ins. Co.

Filed 10/9/26 CERTIFIED FOR PUBLICATION IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA FIFTH APPELLATE DISTRICT THE PEOPLE, F090562 Plaintiff and Respondent, (Super. Ct. No. CR-24-002863) v. THE NORTH RIVER INSURANCE COMPANY et al., OPINION Defendants and Appellants. APPEAL from a judgment of the Superior Court of Stanislaus County. Valli K. Israels, Judge. Jefferson T. Stamp for Defendants and Appellants. Thomas E. Boze, County Counsel, Ciara Asefi, Deputy County Counsel, for Plaintiff and Respondent. -ooOoo- A surety on a forfeited bail bond contends the summary judgment entered against it in accordance with the express requirements of Penal Code section 1306, subdivision (a)1 is invalid. The surety argues the trial court exceeded its jurisdiction by entering the summary judgment in the criminal action in which the bond was posted, rather than a newly opened civil case. This argument raises a novel issue of statutory construction— 1 Undesignated statutory references are to the Penal Code. namely, whether section 1306 impliedly requires the summary judgment on a forfeited bail bond to be entered in a civil case. Subdivision (a) of section 1306 contains five express requirements that must be met to properly enter a summary judgment against a surety that posted a bail bond. The statute does not expressly authorize or prohibit the entry of summary judgment in the criminal action or expressly require trial courts to enter summary judgment in a separate civil case. The basic principles of statutory interpretation, which include the plain meaning rule and the interpretive canon of expressio unius est exclusio alterius, lead us to reject the implied statutory requirement proposed by the surety. In short, if the Legislature had intended to require a new civil case, it would have said so. (See Code Civ. Proc., § 1858 [when construing a statute, courts do not “insert what has been omitted” by the Legislature].) Thus, trial courts may enter summary judgment on a forfeited bail bond in the criminal case or in a new civil case. Because the trial court complied with the bail statute’s express requirements, we affirm the summary judgment. FACTS AND PROCEEDINGS On January 21, 2024, Bad Boys Bail Bonds, acting as the agent of The North River Insurance Company (Surety), posted a $90,000 bail bond for the release of defendant Pablo Flores Valdivia. In accordance with the content requirements of section 1287, subdivision (a), the bond stated: “If the forfeiture of this bond be ordered by the Court, Judgment may be summarily made and entered forthwith against the said THE NORTH RIVER INSURANCE COMPANY for the amount of its undertaking herein as provided by Sections 1305 and 1306 of the Penal Code.” In February 2024, the People filed a felony complaint in Stanislaus County Superior Court naming Valdivia as the only defendant in a criminal action assigned case No. CR-24-002863. The complaint alleged three counts: negligent discharge of a firearm in violation of section 246.3, subdivision (a); carrying a loaded firearm in a public place 2. in violation of section 25850, subdivision (c)(6); and carrying a concealed unregistered firearm in violation of section 25400, subdivision (c)(6). On March 20, 2014, Valdivia failed to appear at his arraignment hearing and the trial court ordered bail forfeited in open court. The next day, the clerk of court mailed a notice of forfeiture to Surety and the bail agent stating the defendant had failed to appear and the court ordered bail forfeited. As a result, the 180-day period (plus five days for mailing), which is sometimes referred to as the appearance period or the exoneration period, was set to expire on September 23, 2024. On September 20, 2024, the bail agent filed a motion under section 1305.4 to extend the appearance period. The trial court granted the motion and extended the appearance period to April 25, 2025. Valdivia was not surrendered before the appearance period lapsed. On July 23, 2025, the clerk filed a “JUDGMENT & NOTICE OF ENTRY OF JUDGMENT” against Surety in the sum of $90,000 plus administrative costs and interest in case No. CR-24-002863. On August 14, 2025, Surety filed a motion to set aside the summary judgment, vacate the bond forfeiture, and exonerate the bail bond. The People filed an opposition, and the matter was argued to the trial court on September 22, 2025. During the hearing, the trial court stated it had never seen a bail agent or surety make the argument that a new civil action needed to be filed to enforce the summary judgment. The court denied the motion. Surety timely appealed. Surety’s opening brief included a certificate of interested entities or persons (Judicial Council Forms, form APP-008) that listed Surety’s parent company, the two individual owners of the bail agent, and the indemnitor on the bail bond. (See People v. The North River Ins. Co. (2025) 111 Cal.App.5th 581, 587, fn. 4 [indemnitor listed in the certificate]; Cal. Rules of Court, rule 8.208(e)(2) [certificate 3. must identify persons who have “a financial or other interest in the outcome of the proceeding”].) The indemnitor was described as the former fiancée of Valdivia. DISCUSSION Surety’s claim of trial court error relies on subdivisions (a) and (c) of section 1306. Surety contends the trial court was obligated to enter summary judgment against it pursuant to section 1306, subdivision (a) once the extended appearance period had lapsed and, when a trial court fails to enter summary judgment within 90 days, “the right to do so expires and the bail is exonerated.” (§ 1306, subd. (c).) These fundamental aspects of section 1306 are not disputed. The dispute arises from Surety’s next contention— namely, that the judgment referred to in section 1306, subdivision (a) must be entered in a new civil case within the 90-day period and a trial court’s attempt to enter summary judgment in the criminal case exceeds the court’s jurisdiction. Applying its statutory interpretation to the procedural history of this case, Surety concludes the summary judgment entered against it in Valdivia’s criminal case exceeded the court’s jurisdiction and should be set aside and, further, the bond should be exonerated under subdivision (c) of section 1306. The People contend the trial court’s jurisdiction over the bail bond is established by the bail statutes, not by filing a civil case. The People argue the bail statutes do not require a separate civil case and quote a 1956 appellate decision stating: “Since 1927 the Penal Code (§§ 1305, 1306) has required the court in which a bail bond has been filed to perform specified acts as a means of fixing liability of bail after the unexcused nonappearance of the defendant. There is no civil action on the bond by the district attorney, as formerly.” (People v. Burton (1956) 146 Cal.App.2d Supp. 878, 881 (Burton), disapproved on another ground in People v. United Bonding Ins. Co. (1971) 5 Cal.3d 898, 907.) The People further argue that the amendments to sections 1305 and 1306 after Burton did not create a civil action requirement. 4.  When, as here, “the relevant facts are undisputed and only legal issues are involved, we conduct an independent review.” (County of Los Angeles v. Financial Casualty & Surety, Inc. (2018) 5 Cal.5th 309, 314.) The questions of statutory interpretation raised by Surety are legal issues and, thus, subject to independent review on appeal. (Davis Boat Manufacturing-Nordic, Inc. v. Smith (2023) 95 Cal.App.5th 660, 672.) I. ENTRY OF SUMMARY JUDGMENT ON A FORFEITED BAIL BOND A. Statutory Text and Its Express Requirements “ ‘The forfeiture of bail and related proceedings are a matter of statutory procedure governed by sections 1305 through 1308.’ ” (County of Los Angeles v. Financial Casualty & Surety, Inc., supra, 5 Cal.5th at p. 314.) Section 1306 provides in relevant part: “(a) When any bond is forfeited and the period of time specified in Section 1305 has elapsed without the forfeiture having been set aside, the court which has declared the forfeiture shall enter a summary judgment against each bondsman named in the bond in the amount for which the bondsman is bound. The judgment shall be the amount of the bond plus costs, and notwithstanding any other law, no penalty assessments shall be levied or added to the judgment. [¶] … [¶] “(c) If, because of the failure of any court to promptly perform the duties enjoined upon it pursuant to this section, summary judgment is not entered within 90 days after the date upon which it may first be entered, the right to do so expires and the bail is exonerated.” Initially, we describe what the bail statutes explicitly require. Before a summary judgment is entered in accordance with section 1306, (1) the bond must have been forfeited and (2) the appearance period must have lapsed without the forfeiture being set aside. When these requirements are met, the summary judgment (3) must be entered by “the court which has declared the forfeiture” of bail; (4) must be “against each bondsman named in the bond”; and (5) must be “in the amount for which the bondsman is bound.” (§ 1306, subd. (a).) These five express requirements were satisfied in this case. 5.  Next, we describe an express prohibition. Section 1306, subdivision (c) bars courts from entering summary judgment more than 90 days after the appearance period has lapsed. Here, the summary judgment was entered 89 days after the appearance period expired and, thus, the express prohibition was not violated. Having described the express requirements and prohibitions, we turn to topics that are not addressed in subdivisions (a) and (c) of section 1306 or other provisions of the bail statutes. Stated broadly, the statutes do not identify the case in which the summary judgment must be entered. Stated in more detail, courts are not required to enter the summary judgment in the criminal case in which bail was posted and are not required to enter summary judgment in a new civil case. Similarly, courts are not prohibited from entering summary judgment in the criminal case or prohibited from entering summary judgment in a newly opened civil case. Due to the absence of statutory language addressing the case in which the summary judgment must (or may) be entered, the trial court’s entry of summary judgment in the criminal case did not violate the literal terms of section 1306. In particular, the court did not do something it was expressly prohibited from doing and it did not fail to do something it was expressly required to do. Based on our determination that the trial court did not act contrary to the statute’s plain (i.e., literal) meaning, we turn to the parties’ arguments about what the Legislature intended to imply. B. Implied Statutory Requirement for a New Civil Case Surety acknowledges the lack of explicit statutory language and contends the summary procedure adopted by the Legislature in 1927 implicitly requires a new civil case. Surety characterizes the opening of a new civil case as one of “the duties enjoined upon” the court as that phrase is used in section 1306, subdivision (c). Surety presents several arguments for inferring the Legislature intended the summary judgment be entered in a new civil case. 6.  1. Procedures Used Before 1927 Before 1927, the method for enforcing a forfeiture of bail under sections 1305 and 1306 was a civil action upon the bond brought by the district attorney. (People v. Philadelphia Reinsurance Corp. (2021) 70 Cal.App.5th Supp. 10, 17.) The civil action could be commenced only after a declaration of forfeiture by the court in which the principal had failed to appear and the lapse of 20 days more during which the nonappearance remained unexcused. (Ibid.) The 1927 amendments to the bail statute purposely significantly changed the character of proceedings for forfeiture of bail by removing bail forfeiture proceedings from the category of judicial forfeitures and placing them within the classification of legislative or statutory forfeitures. (Ibid.) Since 1927, section 1305 and 1306 have required the court in which a bail bond was filed, not the district attorney, to perform specified acts as a means of fixing liability after the defendant’s failure to appear. (Philadelphia Reinsurance Corp., supra, at p. 17.) Surety argues it is undisputed that, prior to the 1927 amendment, the district attorney had to file a new case to enforce the bail bond contract and, while the amendment’s “summary proceeding is clearly designed to expedite that process, no language in the reformed statute permits the filing of the summary judgment in the criminal case.” Surety accurately states the amended statute did not expressly permit the summary judgment to be filed in the criminal case. However, the absence of express authorization does not necessarily establish the Legislature intended to retain a vestige of the scheme that it abolished. Surety attempts to bolster its inference of legislative intent by asserting that “just because the Legislature expedited the procedure for obtaining the civil judgment by requiring the Surety to consent to its entry, this does not mean the trial court was authorized to enter the summary judgment in the criminal case. On the contrary, if the Legislature intended to authorize the entry of summary judgment in the criminal case, it would have explicitly said as much.” This argument in support of an implied 7. requirement (i.e., judgment must be entered in a new civil case) is weak because the Legislature set forth five express requirements (see pt. I.A., ante) relating to the entry of the summary judgment. Thus, Surety’s inference of legislative intent contradicts “the interpretive canon of expressio unius est exclusio alterius — ‘ “the expression of one thing in a statute ordinarily implies the exclusion of other things.” ’ ” (In re Kowalczyk (2026) 19 Cal.5th 593, 618; see Dyna-Med, Inc. v. Fair Employment & Housing Com. (1987) 43 Cal.3d 1379, 1391, fn. 13.) As a result, the stronger inference is that if the Legislature had intended to require the entry of summary judgment in a new civil case, it would have included such a requirement with the other express requirements. (See Code Civ. Proc., § 1858 [principle of statutory construction that a court not “insert what has been omitted” by the Legislature].) In addition, the interpretive canon and Code of Civil Procedure section 1858 provide the basis for rejecting Surety’s argument about a statute of limitations. In that argument, Surety (1) characterizes the 90-day period in which the summary judgment must be entered (§ 1306, subd. (c)) as a statute of limitations; (2) asserts a statute of limitations normally sets the time within which proceedings must be commenced once a cause of action accrues; (3) a cause of action is simply the obligation sought to be enforced against the defendant; and (4) the summary judgment procedure involves the People enforcing Surety’s payment obligation under the bail bond. From this foundation, Surety concludes: “By any assessment of how civil litigation works, this required a new civil case against Surety to be commenced.” We conclude the inferences of legislative intent drawn in this argument are too tenuous to overcome the inferences of intent supported by the canon of expressio unius est exclusio alterius and Code of Civil Procedure section 1858. 2. Case Law Surety cites appellate cases that it interprets as involving the entry of the summary judgment in a separate civil action. (See People v. American Surety Co. (2025) 112 8. Cal.App.5th 71, 75 [Santa Barbara County]; People v. Philadelphia Reinsurance Corp., supra, 70 Cal.App.5th Supp. at p. 21 [San Diego County]; People v. The North River Ins. Co. (2020) 53 Cal.App.5th 559, 567 [Los Angeles County]; People v. United States Fire Ins. Co. (2015) 242 Cal.App.4th 991 [Tulare County; summary judgment’s caption referred to civil case No. VCU257707 and criminal case No. VCF286395B]; County of Los Angeles v. Amwest Surety Ins. Co. (1983) 147 Cal.App.3d 961.) From these cases, Surety infers the opening of a new civil action is mandated by the statute, rather than simply allowed. The cases cited by Surety are not authority for the existence of the implied requirement proposed by Surety. The decisions do not expressly discuss whether or not a summary judgment on a forfeited bail bond must be entered in a new civil case. “Language used in any opinion is of course to be understood in the light of the facts and the issue then before the court, and an opinion is not authority for a proposition not therein considered.” (Ginns v. Savage (1964) 61 Cal.2d 520, 524, fn. 2; Geiser v. Kuhns (2022) 13 Cal.5th 1238, 1252.) Furthermore, appeals filed with the Fifth District show the Stanislaus County Superior Court has, without challenge until this case, followed the practice of entering judgment in the criminal case in which the forfeiture occurred. (E.g., People v. The North River Ins. Co., supra, 111 Cal.App.5th 581 [case No. CR-22-004262]; People v. Accredited Surety & Casualty Co., Inc. (2022) 79 Cal.App.5th 656 [case No. CR-18- 005227]; People v. Accredited Surety & Casualty Co., Inc. (2021) 65 Cal.App.5th 122 [case No. CR-18-000990]; People v. The North River Ins. Co. (2020) 58 Cal.App.5th 300 [case No. 1489891]; People v. Accredited Surety & Casualty Co. (2012) 203 Cal.App.4th 1490 [case No. 1250722].) The cases cited by Surety and the cases listed in the preceding paragraph show that some trial courts open a new civil case and others enter the summary judgment in the criminal case. Thus, the conduct of the state’s trial courts suggests those courts have the 9. option of entering the summary judgment on a forfeited bail bond in the criminal case or in a newly opened civil case. Stated another way, the matter is committed to the discretion of the trial court. 3. Burton and Inferences of Legislative Intent Here we consider the only case cited by the parties that discusses the filing of a separate civil action—Burton, supra, 146 Cal.App.2d Supp. 878. In that case, the court described the 1927 amendment to the bail statutes and stated: “There is no civil action on the bond by the district attorney, as formerly.” (Id. at p. 881.) The People contend that statutory amendments after Burton—particularly those made in 1965 and 1967—did not contradict Burton’s statement that there is no civil action on the bond. Thus, the People argue the limited scope of the amendments supports the inference that the Legislature did not intend to require the summary judgment be entered in a new civil action. Surety contends Burton did not obviate the need for a separate civil case, arguing that the opinion addressed a question about the applicable statute of limitations and, thus, did not authorize or consider the propriety of entering a summary judgment in the criminal case. We agree that the court in Burton did not decide whether it was proper to file the summary judgment on a forfeited bail bond in the criminal case. Therefore, Burton is not precedent for a court’s authority to do so. Our analysis of Burton does not end there. We proceed to the principle of statutory construction that “ ‘[t]he Legislature is presumed to know about existing case law when it enacts or amends a statute.’ ” (People v. Rhodius (2025) 17 Cal.5th 1050, 1062; Los Angeles Unified School Dist. v. Superior Court (2023) 14 Cal.5th 758, 778 [courts generally presume the Legislature is aware of appellate court decisions].) Based on this presumption, courts further presume that the Legislature enacted or amended a statute against the backdrop of prior judicial decisions. (See People v. Overstreet (1986) 42 Cal.3d 891, 897.) The statement in Burton that there is no civil action on the bond has stood for 70 years without being addressed by the Legislature. As a result, we conclude 10. the Legislature’s failure to abrogate that statement provides some (though far from conclusive) support for the inference that the Legislature did not intend to mandate the entry of the summary judgment in a new civil case. 4. The Court’s Fundamental Jurisdiction This court’s bail bond decisions have addressed the distinction between jurisdiction in a fundamental sense, which refers to jurisdiction over the subject matter and over the parties, and acts taken by a court in excess of its jurisdiction, which are acts contrary to the authority conferred by the bail statutes. (People v. Accredited Surety & Casualty Co., Inc., supra, 79 Cal.App.5th at pp. 664–665; see People v. The North River Ins. Co., supra, 58 Cal.App.5th at pp. 312–313.) When a court lacks jurisdiction in a fundamental sense, any judgment entered in the matter is void. In comparison, when a court has fundamental jurisdiction, but acts in excess of its statutory authority, the ensuing judgment is merely voidable. (People v. The North River Ins. Co., supra, at p. 312.) Stated in chronological terms, a trial court has fundamental jurisdiction when it obtains (1) personal jurisdiction over the surety and (2) subject matter jurisdiction over the bail bond. (People v. The North River Ins. Co., supra, 58 Cal.App.5th at pp. 314– 315.) A court obtains personal jurisdiction over a surety when the surety’s bond is posted in the criminal case. (Id. at p. 315.) Similarly, a court has subject matter jurisdiction over the “ ‘ “bail bond from the point that it is issued until the point it is either satisfied, exonerated, or time expires to enter summary judgment after forfeiture.” ’ ” (Ibid.) In this case, when the trial court entered the summary judgment, it had personal jurisdiction over Surety and had subject matter jurisdiction over the bail bond. Thus, fundamental jurisdiction existed in the context of the criminal case. The fact the Legislature gave trial courts fundamental jurisdiction in such situations supports the inference that it is permissible for trial courts to enter summary judgment in the criminal case. Stated another way, it is not reasonable to infer the Legislature granted 11. fundamental jurisdiction and impliedly restricted the court’s authority to enter summary judgment. 5. The Civil Nature of Bail Bond Proceedings Surety’s motion to set aside the summary judgment quoted the following statement by the Supreme Court: “While bail bond proceedings occur in connection with criminal prosecutions, they are independent from and collateral to the prosecutions and are civil in nature.” (People v. American Contractors Indemnity Co. (2004) 33 Cal.4th 653, 657.) The People refer to this statement and argue that the civil character of bail forfeiture proceedings does not translate into a requirement that a new civil case be filed. We agree the Supreme Court’s description of bail bond proceedings as civil in nature does not support the need to file a civil case before entering summary judgment. The forfeiture of the bail bond, the notice of a forfeiture to the surety and bail agent, and any extension of the appearance period are all proceedings of a civil nature that occur in the criminal case. If those proceedings of a civil nature can occur in a criminal case, it is logical to infer a subsequent step also civil in nature—namely, the entry of summary judgment—can occur in the criminal case. Therefore, we conclude the statement made in American Contractors does not justify recognizing an implied requirement that summary judgment be entered in a new civil case. 6. Code of Civil Procedure Section 1138 and 1139 “A summary judgment in a bail forfeiture is a consent judgment entered without a hearing and the proceedings are not adversarial.” (People v. American Contractors Indemnity Co. (2015) 238 Cal.App.4th 1041, 1047.) Surety refers to this principle and argues the agreed procedure for summary judgments on forfeited bail bonds without any hearing is analogous to an agreed case submitted for a judgment by the court without any pleadings. The procedure for an agreed case is contained in Code of Civil Procedure section 1138, which states in full: 12.  “Parties to a question in difference, which might be the subject of a civil action, may, without action, agree upon a case containing the facts upon which the controversy depends, and present a submission of the same to any Court which would have jurisdiction if an action had been brought; but it must appear, by affidavit, that the controversy is real and the proceedings in good faith, to determine the rights of the parties. The Court must thereupon hear and determine the case, and render judgment thereon, as if an action were depending.” Code of Civil Procedure section 1139 provides in full: “Judgment must be entered as in other cases, but without costs for any proceeding prior to the trial. The case, the submission, and a copy of the judgment constitute the judgment roll.” A secondary authority describes agreed cases as “a special proceeding whereby parties to a real controversy may, without going to trial, present an agreed statement of the facts of the case to the court and receive a binding judgment on the issues of law.” (Moore & Thomas, Cal. Civil Practice Procedure (2026) Submission of Agreed Case, § 19:1 [nature and purpose of agreed case].) “[T]he parties submit an agreed statement of the controversy to a court for determination before the action has been filed.” (Ibid.) In other words, Code of Civil Procedure section “1138 provides for the submission of a controversy without any action being filed.” (Moore & Thomas, supra, § 19:4, italics added.) Thus, an agreed case is not an “action,” which is defined as “an ordinary proceeding in a court of justice by which one party prosecutes another for the declaration, enforcement, or protection of a right, the redress or prevention of a wrong, or the punishment of a public offense.” (Code Civ. Proc., § 22, italics added.)2 Contrary to Surety’s argument, we conclude the procedures for initiating and concluding an agreed case are not analogous to the entry of a summary (i.e., consent) judgment on a forfeited bail bond. The entry of the summary judgment, unlike the judgment rendered an agreed case, does not require the court to “hear and determine the 2 Stated another way, the concept of a “case” encompasses more than “actions” and includes proceedings known as “agreed cases.” 13. case.” (Code Civ. Proc., § 1138.) More significantly, in matters involving forfeited bail bonds, there is a pending criminal case in which the trial court has personal jurisdiction over the surety and subject matter jurisdiction over the bail bond. As a result, the summary judgment need not be rendered “as if an action were depending” because the criminal action is pending. (Ibid., italics added.) Consequently, we conclude Code of Civil Procedure section 1138 does not require a new civil case to be opened for the entry of a summary judgment on a forfeited bail bond. Further, it does not provide an apt analogy from which it is reasonable to infer the Legislature intended section 1306 to impliedly require the opening of a new civil case for the entry of the summary judgment. 7. Section 1308 Surety argues section 1308 requires a new civil case to be filed. Subdivision (a) of section 1308 provides: “No court or magistrate shall accept any person or corporation as surety on bail if any summary judgment against that person or corporation entered pursuant to Section 1306 remains unpaid after the expiration of 30 days after service of the notice of the entry of the summary judgment, provided that, if during the 30 days an action or proceeding available at law is initiated to determine the validity of the order of forfeiture or summary judgment rendered on it, this section shall be rendered inoperative until that action or proceeding has finally been determined, provided that, if an appeal is taken, an appeal bond is posted in compliance with Section 917.1 of the Code of Civil Procedure.” This provision describes proceedings that are available after the judgment has been entered and the surety has been served with notice of entry of the summary judgment. It does not explicitly require a new civil case be opened before the entry of the summary judgment. Furthermore, section 1308 makes clear that the Legislature knows how to require a new action or proceeding in the context of bail bond forfeitures and, consequently, supports the inference that the Legislature’s silence means it did not intend to require a new civil case be opened for the entry of the summary judgment. (See Siam v. Superior Court (2026) 118 Cal.App.5th 67, 84 [statutory provision demonstrated the 14. Legislature knew how to limit the trial court’s authority and the absence of a limitation in another provision indicated it did not intend any such limitation to apply].) In other words, the requirements in section 1308 support the conclusion that “had the Legislature intended to require a [new civil case], it would have said so.” (In re N.R. (2023) 15 Cal.5th 520, 553.) 8. Summary: The Plain Meaning Rule Applies As a general rule of statutory construction, courts usually adopt the plain (i.e., literal) meaning of the statutory language. (Hughes v. Board of Architectural Examiners (1998) 17 Cal.4th 763, 775; Honchariw v. County of Stanislaus (2013) 218 Cal.App.4th 1019, 1027.) “The plain meaning rule is subject to exceptions.” (TRC Operating Co. Inc. v. Chevron USA, Inc. (2024) 102 Cal.App.5th 1040, 1068.) The exceptions apply when reading the statutory text literally (1) would produce absurd consequences that the Legislature clearly did not intend or (2) would frustrate the manifest purposes of the legislation. (Ibid.; see Merced Irrigation Dist. v. Superior Court (2017) 7 Cal.App.5th 916, 924; see also, Bob Jones University v. United States (1983) 461 U.S. 574, 586 [a well-established canon of statutory construction provides that literal language should not defeat the plain purpose of the statute].) Surety has not attempted to establish the first exception to the plain meaning rule applies to section 1306 by showing it would be absurd to allow the entry of a summary judgment in the criminal case. Further, our independent review has not identified an absurd consequence that would result from allowing trial courts the option of entering the summary judgment in either the criminal case or in a newly opened civil case. In addition, Surety’s arguments do not establish that allowing trial courts the option would frustrate a manifest purpose of the bail bond statutes. Surety recognizes that the 1927 amendment was designed to streamline the forfeiture procedures and allowing trial courts flexibility promotes, rather than frustrates, the goal simplifying the procedures. 15.  Consequently, we conclude the plain meaning rule applies to the question of statutory interpretation presented in this appeal. In the circumstances presented, it is inappropriate to infer the Legislature intended to impose the implied requirement proposed by Surety. Consequently, the trial court did not violate the bail statutes when it entered the summary judgment in the criminal case. DISPOSITION The judgment is affirmed. Respondent shall recover its costs on appeal. FRANSON, Acting P. J. WE CONCUR: SNAUFFER, J. DE SANTOS, J. 16.