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People v. Jones
231 Cal. App. 4th 1257
| Cal. Ct. App. | 2014
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Background

  • Jones was arrested for DUI causing bodily injury after a blood sample was drawn at 1:10 a.m. over his objection and without a warrant.
  • Jones admitted to being on active probation with a search-and-seizure condition; records later confirmed PRCS supervision with a search term.
  • The McNeely decision (2013) held that a natural dissipation of alcohol is not an automatic exigency justifying a warrantless blood draw; it was issued after Jones’s arrest.
  • The trial court denied Jones’s motion to suppress; no case-specific exigent circumstances were found.
  • The court held McNeely does not retroactively apply to preexisting cases, and that PRCS conditions permit warrantless searches and blood draws, affirming the denial of suppression.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Does McNeely apply retroactively to suppress the blood draw? Jones's position: McNeely requires suppression. Jones's position: McNeely controls; retroactive effect applies. McNeely does not apply retroactively; suppression denied.
Does the postrelease community supervision (PRCS) search condition authorize a warrantless blood draw? People contend PRCS permits searches including blood draws. Jones argues PRCS cannot authorize such bodily intrusions without more. PRCS search condition provides independent basis to permit the blood draw.

Key Cases Cited

  • Missouri v. McNeely, 133 S. Ct. 1552 (U.S. 2013) (rejected per se exigency for warrantless blood tests in DUI cases)
  • Schmerber v. California, 384 U.S. 757 (U.S. 1966) (permitted warrantless blood draw under certain conditions due to evanescent alcohol)
  • Maryland v. King, 133 S. Ct. 1958 (U.S. 2013) (recognized blood draws as reasonable in certain contexts; compared to buccal swabs)
  • Reyes v. Superior Court, 19 Cal.4th 743 (Cal. 1998) (parole/probation search conditions may permit warrantless searches)
  • Griffith v. Kentucky, 479 U.S. 314 (U.S. 1987) (retroactivity framework for new rules in criminal prosecutions)
Read the full case

Case Details

Case Name: People v. Jones
Court Name: California Court of Appeal
Date Published: Nov 26, 2014
Citation: 231 Cal. App. 4th 1257
Docket Number: A140054
Court Abbreviation: Cal. Ct. App.