People v. Mathews
A146652
| Cal. Ct. App. | Oct 25, 2017Background
- Defendant Damari Mathews was charged with second‑degree robbery and related firearm offenses after a robbery and a shooting; he was convicted and sentenced to an aggregate 13 years.
- Mathews was dropped off at Highland Hospital with gunshot wounds; hospital staff stored his watch, cash, clothing, and a cell phone in a hospital safe.
- Officers contacted Mathews in a trauma room; he first gave a false name (“Damari/Omari Johnson”), then later provided his true name. A record check on the false name initially failed to reveal his probation search condition; a later check on his true name showed he was on searchable probation.
- Officer Ballard‑Geiger seized the phone and other property from the hospital safe; the phone’s records later tied it to the robbery vicinity. Mathews moved to suppress the items and fruits of the phone search.
- The trial court denied the suppression motion (relying on People v. Watkins), denied Mathews’s Pitchess motion for officer personnel records, awarded presentence custody and conduct credits, and entered judgment; the Court of Appeal affirmed with a minor abstract‑of‑judgment correction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| 1) Fourth Amendment suppression of phone and fruits | Prosecution: search/seizure lawful because defendant’s probation search condition justified seizure once known; estoppel applies | Mathews: seizure occurred before officers learned of probation status and after he gave false name; exclusion required | Court: Mathews estopped under Watkins to challenge phone seizure because officers received record check results based on the false name before seizure; phone and derived evidence admissible |
| 2) Suppression of officer observations and clothing | Prosecution: observations harmless or lawful; hospital records independently established injuries | Mathews: officer observed wounds/clothes and seized items without knowledge of search condition, violating Fourth Amendment | Court: any error admitting officer’s observations was harmless beyond a reasonable doubt (medical records independently showed injuries) |
| 3) Pitchess discovery of officers’ personnel records | Prosecution: no good cause shown; reports’ wording not materially misleading | Mathews: requested records would show fabrication/misstatements and impeach officers about where/when property was seized | Court: summary denial not an abuse of discretion—defendant’s affidavit failed to show materiality or how records would impeach the officers on the asserted theory |
| 4) Presentence custody and conduct credits calculation | Prosecution: trial court correctly computed 648 days custody, 97 days conduct credits (total 745) | Mathews: probation report overstated custody; claimed different custody/conduct totals | Court: trial court’s arithmetic correct given record (accounting for a brief September 2013 release); credits affirmed |
Key Cases Cited
- People v. Watkins, 170 Cal.App.4th 1403 (Cal. Ct. App.) (defendant who lies about identity may be estopped from suppressing evidence when record check based on lie prevents discovery of searchable probation)
- Myers v. Superior Court, 124 Cal.App.4th 1247 (Cal. Ct. App.) (officer’s failure to conduct record check can require suppression despite defendant’s misstatements)
- Pitchess v. Superior Court, 11 Cal.3d 531 (Cal. 1974) (defendant may compel limited discovery of officer personnel records upon showing of good cause)
- Wong Sun v. United States, 371 U.S. 471 (U.S. 1963) (exclusionary rule and fruit‑of‑the‑poisonous‑tree doctrine)
- People v. Coffman and Marlow, 34 Cal.4th 1 (Cal. 2004) (inevitable discovery doctrine and limits of exclusionary rule)