California Supreme Court

People v. Brown

March 27, 2023

Summary

The court held that a trial court abuses its discretion by denying a continuance of a suppression hearing when it is reasonably foreseeable that denial will result in dismissal because the prosecution cannot proceed without the challenged evidence, unless dismissal would further justice. The prosecution retains the burden to show that the evidence is indispensable, and the trial court must independently assess that showing rather than rely solely on the prosecutor's representation. Applying that rule, the court affirmed the conviction but reversed the Court of Appeal's contrary judgment.