People v. Brown
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The Supreme Court reversed the decision of the court of appeal affirming the trial court's judgment convicting Defendant of loitering for purposes of prostitution, holding that the court of appeal erred in ruling that trial courts retain authority to deny a continuance unsupported by good cause even if the decision will foreseeably result in the case's dismissal for lack of evidence.
Defendant filed a motion to suppress, but the prosecutor orally requested a continuance on the date of the suppression hearing due to the unavailability of a witness. The trial court denied the motion for a continuance for lack of good cause and then granted Defendant's motion to suppress. Upon reconsideration, however, the trial court vacated its prior orders and denied the suppression motion. Defendant ultimately agreed to a "slow plea." The court of appeals affirmed, holding that the trial court did not err in reconsidering its continuance and suppression rulings. The Supreme Court reversed the court of appeal's decision but affirmed Defendant's conviction, holding (1) the principles set forth in People v. Ferguson, 218 Cal.App.3d 1173 (1990), apply when the People are unable to proceed with a hearing on a suppression motion; and (2) the trial court's denial of Defendant's suppression motion "reposed within the court's sound discretion."
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