California v. Byers
Annotate this CaseThe trial court denied defendant David Byers’s motion to suppress evidence. Defendant then pleaded guilty to possession of cocaine for sale and misdemeanor possession of nitrous oxide for the purpose of intoxication. The court imposed the upper term of four years on count 1, stayed sentence on count 2 under section 654, and then designated a split sentence of one year in jail followed by three years of mandatory supervision. On appeal, defendant contended law enforcement’s warrantless entry into his apartment pursuant to his absent housemate’s consent violated the Fourth Amendment. Related to these arguments, defendant requested that the Court of Appeal independently review the sealed transcript of the trial court’s in camera hearing, as well as the documents reviewed by the court in that hearing. The Court concluded substantial evidence supported the court’s finding defendant’s housemate’s consent was voluntary. But the Court held the trial court abused its discretion by excluding evidence on whether the officers complied with the knock-notice requirement. Nevertheless, the error was harmless because the appropriate remedy for a knock-notice violation here was not the suppression of the seized evidence, which was the only relief requested. The Court affirmed the trial court in all other respects.
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