California v. Patton
Annotate this CaseDefendant Kayvon Patton pleaded guilty to grand theft of personal property after he joined friends and stole cell phones and other electronic devices from an electronics store. Among the conditions of his probation was a condition subjecting his electronic devices to warrantless search. Patton challenged this condition as unreasonable under California v. Lent, 15 Cal.3d 481 (1975) and constitutionally overbroad. In its initial opinion, the Court of Appeal rejected the State’s argument that Patton's appeal should have been dismissed for failure to obtain a certificate of probable cause. The Court then concluded the electronics search condition was valid under Lent and not overbroad. After the appellate court’s decision, the California Supreme Court issued In re Ricardo P., 7 Cal.5th 1113 (2019), clarifying when an electronics search was is reasonably related to the probationer's future criminality under Lent. The Court of Appeal granted Patton's petition for rehearing and allowed both parties to file supplemental briefs concerning the effect of Ricardo P. Upon rehearing the Court of Appeal concluded, as before, that Patton did not need a certificate of probable cause to challenge the electronics search condition on appeal. Despite a boilerplate waiver of appellate rights in his plea agreement, he did not waive his right to challenge a later-imposed condition of probation that was not referenced in that agreement. Accordingly, his appeal was based on "[g]rounds that arose after entry of the plea and do not affect the plea's validity." The Court found the electronics search condition was validly imposed under Lent's first prong because it related to Patton’s underlying crime. Ricardo P. did not alter this analysis. Moreover, because the nature of Patton's offense means that some electronics search condition could constitutionally be imposed, the condition was not facially overbroad. Accordingly, the Court affirmed.
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