People v. Rodriguez CA6, H051398

Jaime Rodriguez was charged with possession of a machine gun after police discovered a firearm in a locked container in the trunk of his girlfriend's car, which crashed into a house.
After the collision, Rodriguez and his girlfriend fled the scene, leaving the car and lockbox behind.
When speaking with police the next day, Rodriguez and his girlfriend falsely reported the car as stolen, presenting injuries consistent with the crash.
At the preliminary hearing, Rodriguez moved to suppress the firearm found in the lockbox, arguing he retained an expectation of privacy.
The court denied the suppression motion, finding the vehicle and lockbox were abandoned, and Rodriguez pleaded no contest to an amended charge.
On appeal, Rodriguez challenged the suppression ruling and disputed a possible erroneous probation order, but the appellate court affirmed the judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Suppression of Evidence	Argument that items were abandoned, therefore no reasonable privacy expectation	Claimed a continuing expectation of privacy in the locked box, despite leaving it in trunk	Held Rodriguez abandoned privacy interest by fleeing the scene and not asserting claim to lockbox
Expectation of Privacy in Lockbox	No privacy because of abandonment and false report of theft	Ownership and locked status demonstrates expectation of privacy	Court agreed privacy existed initially but was relinquished due to abandonment
Use of Hearsay Evidence at Suppression	Admissible under preliminary hearing standards	Hearsay should be excluded for suppression purposes	Court found sufficient admissible evidence outside of contested hearsay
Validity of Probation/Commitment Order	File-endorsed probation order reflects actual court decision	Claimed an unsigned, digitally signed order sentenced him to jail instead	Held that the unfiled, unsigned commitment order was a nullity and the filed probation order controlled

People v. Parson, 44 Cal.4th 332 (Cal. 2008) (defines the standard for abandonment and loss of expectation of privacy).
People v. Bryant, Smith and Wheeler, 60 Cal.4th 335 (Cal. 2014) (describes legitimate expectation of privacy under totality of circumstances).
People v. Covarrubias, 1 Cal.5th 838 (Cal. 2016) (articulates standard for reviewing factual findings for substantial evidence).
People v. Maury, 30 Cal.4th 342 (Cal. 2003) (explains subjective expectation of privacy can be proven by circumstantial evidence).