People v. Juarez CA6, H051410

Jose Matthew Juarez was stopped by a Santa Cruz County Sheriff's sergeant responding to a report of a possible suicide attempt; Juarez and another man were found parked illegally on a highway overpass late at night.
When approached, the officer observed what appeared to be a potential weapon in Juarez’s jacket pocket; after backup was requested, the officer conducted a patdown and found a loaded, unregistered firearm.
Juarez was charged with carrying a loaded unregistered firearm (Penal Code § 25850) and carrying a concealed firearm (Penal Code § 25400).
He sought suppression of the firearm evidence, challenged the constitutionality of California’s licensing scheme under New York State Rifle & Pistol Assn. v. Bruen, and argued he was entitled to custody credits while on electronic monitoring.
Trial court denied Juarez’s suppression motion and constitutional challenges, convicted him after a no contest plea, denied additional custody credits, and Juarez appealed.

Issue	Juarez’s Argument	State’s Argument/Response	Held
Lawfulness of Detention/Patdown (Motion to Suppress)	Detention was based on resolved suicide report, not credible traffic investigation; patdown unjustified.	Officer had reasonable suspicion of illegal parking and safety concern; detention and search were justified.	Detention and patdown were lawful.
Second Amendment—Constitutionality of § 25850	CA licensing scheme (at time) unconstitutional due to “good cause” and training reqs per Bruen.	"Good cause" requirement (now repealed) is severable; remaining reqs are constitutional under Bruen.	Licensing scheme valid, conviction affirmed.
Retroactivity of Severance Doctrine	Severing "good cause" post-Bruen should not retroactively cure his arrest under then-existing law.	Severability operates even retroactively for facial challenges; only “as applied” claims might differ.	No retroactivity bar; no relief for Juarez.
Equal Protection for Custody Credits on Monitoring	Private program (Options) is equivalent to county program (CAPS); denial of credits violates equal protection.	No evidence that Options satisfies statutory requirements, or that a required contract exists.	No equal protection violation found.

Terry v. Ohio, 392 U.S. 1 (1968) (establishing standard for stop-and-frisk based on reasonable suspicion)
Whren v. United States, 517 U.S. 806 (1996) (probable cause for traffic stop is sufficient under the Fourth Amendment)
District of Columbia v. Heller, 554 U.S. 570 (2008) (Second Amendment protects individual right to keep and bear arms)
New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 597 U.S. 1 (2022) (striking down "proper cause" requirements for concealed carry)
McDonald v. City of Chicago, 561 U.S. 742 (2010) (Second Amendment incorporated against states via Fourteenth Amendment)
People v. Simon, 1 Cal.5th 98 (Cal. 2016) (standards for motion to suppress evidence)