People v. Brown, 525 P.3d 1036

July 13, 2016: Officer Yasin detained Brown in an area known for prostitution; Brown made statements and produced condoms; Brown filed a suppression motion under §1538.5.
On the suppression hearing date, the prosecutor (without court notice) told the subpoenaed officer he could skip court to conduct an interview in another matter; the officer did not appear and the prosecutor moved for a continuance.
The trial court denied the continuance for lack of good cause, granted the suppression motion, and set trial; Brown later withdrew her waiver and the speedy-trial deadline controlled scheduling.
The People moved for reconsideration relying on People v. Ferrer; the court vacated its orders, held a new suppression hearing, denied suppression, and Brown entered a judicial "slow plea," was convicted and placed on probation.
The Court of Appeal disagreed with Ferrer and held trial courts may deny continuances unsupported by good cause even if dismissal is foreseeable; the California Supreme Court granted review.
Supreme Court holding: trial courts must generally grant a continuance of a suppression hearing when denial will reasonably foreseeably lead to dismissal and the continuance can be granted without violating speedy-trial rights; prosecution bears the burden to show inability to go forward without the evidence and the court must independently determine foreseeability; sanctions short of dismissal remain available for procedural noncompliance.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a trial court may deny a continuance of a suppression hearing solely for lack of good cause when such denial will foreseeably cause dismissal	People: Ferrer requires granting a continuance when the prosecution says it cannot proceed; continuance should be granted if it fits within speedy-trial windows	Brown: Court may deny continuance for lack of good cause; courts retain discretion to dismiss under §1385	Court: Denial is an abuse of discretion when dismissal is reasonably foreseeable and continuance can be granted without violating speedy-trial rights; dismissal still allowed if in furtherance of justice; People must show inability to proceed and court must independently assess foreseeability
How sections 1050/1050.5 interact with dismissal authority and sanctions	People: §1050 is directory; Assembly Bill No. 1273 (2003) codified that continuance rules should not mandate dismissal; courts should not defeat prosecutions by denying continuances within statutory timeframes	Brown: §1050 still requires good cause and courts have authority to deny continuances and dismiss under §1385	Court: §1050/1050.5 require good-cause procedures and permit sanctions (fines, discipline) but do not themselves authorize dismissal; dismissal power exists under §1385 but is constrained by case law and legislative intent to avoid dismissals that merely punish procedural lapses

People v. Ferguson, 218 Cal.App.3d 1173 (Cal. Ct. App.) (denial of continuance leading to dismissal within speedy-trial window was abuse of discretion)
People v. Ferrer, 184 Cal.App.4th 873 (Cal. Ct. App.) (applies Ferguson principles to suppression hearings; continuance required when denial will foreseeably cause dismissal)
People v. Henderson, 115 Cal.App.4th 922 (Cal. Ct. App.) (extends Ferguson reasoning to preliminary hearings and statutory timeframes)
People v. Orin, 13 Cal.3d 937 (Cal. 1975) (section 1385 furtherance-of-justice balancing between defendant rights and societal interests)
People v. Kessel, 61 Cal.App.3d 322 (Cal. Ct. App.) (dismissing when continuance would fit within 1382 grace period was improper)
People v. Engram, 50 Cal.4th 1131 (Cal. 2010) (explains directory/mandatory distinction in §1050 and deference to trial-court docket control)