By Yenah Lee
WOODLAND, CA – Yolo County Superior Court Judge Sonia Cortés has ruled a man who was charged with possession of methamphetamine and a methamphetamine pipe did not have his rights violated because the judge believed there was a good faith belief by the officer when the accused’s vehicle was searched during a traffic stop.
The defense argued people of color are often victims of these kinds of mistakes by police. The prosecution and judge rejected the allegation.
The accused was stopped in Woodland by Officer Erik Medina for having an expired registration for his vehicle.
During Officer Medina’s direct examination, the officer made a correction to his summary report that the accused was actually on “mandatory probation” and not “searchable probation” as he wrote based on information provided by dispatch.
Addressing the basis of Officer Medina’s search, Deputy Public Defender Danielle Craig asked whether dispatch mentioned to him over the radio that the accused was “searchable.”
Officer Medina then clarified that he added ‘searchable’ in his report and conducted a search on the accused because dispatch told him over the radio that the accused was under mandatory supervision and sent a CAD log “that stated that [the accused] was on searchable probation.”
DPD Craig then asked why Officer Medina called probation after the arrest and conducting a search of the accused. Medina said it was because the accused was violating his probation, but found out from probation that “(the accused) was not showing up on their list” and the department was “unsure if he was still on probation.”
Officer Medina’s body cam was then played in court to review the night of the accused’s arrest and search. In the video, Medina is heard asking the accused whether he is on probation or parole immediately after pulling him over for his expired vehicle registration. The accused responds he was on probation for methamphetamine.
Taking note of this, DPD Craig asked whether Officer Medina asked everyone he pulled over for traffic stops if they were under probation or parole, to which he replied that he did for almost every vehicle. She then followed up by inquiring what the officer’s determining factors are for asking if an individual is under probation or not.
Officer Medina stated his determining factors are the time of day and “the clutteredness of one’s car,” but then paused to say that “it’s [just] a question [he] choose[s] to ask.”
Following his cross-examination, the DDA asked whether Medina believed mandatory supervision, the type of probation the accused had, was always searchable.
Officer Media said yes, as the previous cases he was involved in for sales of methamphetamine led him to believe that the accused was searchable. He also re-clarified he used dispatch’s CAD information prior to arresting and searching the accused.
After the officer’s re-direct, the prosecution began their closing arguments claiming Medina’s traffic stop was reasonable and a valid good faith belief of the accused being on searchable probation was present, even if the officer’s initial belief of mandatory supervision being searchable was incorrect.
The prosecution cited People v. Downing (1995) as justification for not excluding the evidence produced from the stop and search due to the exclusionary rule. Since there was an error made by probation maintaining the database where Medina utilized the information from, the prosecution argued the officer had reasonable grounds to believe that the accused was under searchable probation.
“Officer Medina, at that point, saw [the CAD] result [and] had a reasonable, good faith belief that the defendant was searchable. He performed a reasonable…search of [the accused’s] vehicle,” claimed the DDA.
DPD Craig said, in her closing argument, good faith did not exist in this case and the suppression motion should be enacted based on two reasons: Officer Medina did not know whether the accused had a search condition at the time of the search and that the accused was not on probation or parole at the time of the search.
To support her argument, DPD Craig cited People v. Rosas (2020) and People v. Ramirez (1983).
Based on People v. Rosas, DPD Craig argued an officer’s belief that someone is searchable is not enough; “the officer has to know at the time they conducted the search that there is a search condition associated with that individual.”
DPD Craig highlights People v. Ramirez as the accused was not on probation in August 2023, which was the time of the search. He was taken off probation in January 2023. However, police records, such as dispatch’s CAD logs officer Medina relied on for his search, did not reflect that due to the oversight by the Yolo County Probation Department that didn’t update the accused’s file.
“The whole purpose of the exclusionary rule is to deter bad police conduct,” argued DPD Craig. “One of the issues that People v. Ramirez discusses is that failure to keep accurate record-keeping is one of the very deterring effects that the exclusionary rule is there for.”
DPD Craig asserted the error was made by a department within the same county as Officer Medina’s police department brings questions to the credibility of his testimony and evidence. She declared that the good faith exception does not protect evidence when the law enforcement is at fault by providing inaccurate information.
“We have two issues in this case and I think that under either theory that this court can find that there was a Fourth Amendment violation,” closed DPD Craig.
In their response, the prosecution maintained it is “not negligence that warrants exclusion (of evidence),” but a deliberate or pattern of mistakes. According to the DDA, Officer Medina reasonably depended on the information provided to him.
Defense countered the People’s final remarks by sharing their concerns for what kind of practices would be considered reasonable if the suppression motion was not approved in this case.
DPD Craig referenced Medina’s testimony where he mentioned that he sporadically asked individuals whether they are on probation or parole. She argued people of color and poor individuals are “asked (this question) more frequently and routinely,” and denying the suppression motion could allow “an open door for free search of a vehicle” and create further issues if there were to be more inaccurate records officers may rely on in the future.
The prosecution commented “it’s not the court’s job to make policy decisions, that’s the job of the legislature.”
Judge Cortés concluded the hearing by denying the motion to suppress Officer Medina’s testimony and found evidence “supporting the officer having a good faith belief that the accused] was on searchable probation given the information he received.”