People v. Turner, 13 Cal. App. 5th 397

Early morning at a 24-hour Nation's restaurant: Turner was found sleeping/slouched in a booth with a duffel bag; manager repeatedly asked him to leave and later requested arrest for trespassing.
Officer Niemi asked Turner to leave, removed Turner's duffel bag to outside the restaurant, and placed Turner under arrest after the manager signed a citizen-request for prosecution.
Turner's bag was inventoried about 18 hours later due to a miscommunication; the inventory revealed a loaded .38 revolver, a 50‑round box (44 rounds) of .38 ammunition, and ~3 grams of methamphetamine in a pill bottle.
Turner moved to suppress the evidence, arguing lack of probable cause for the arrest; the magistrate denied the motion and the trial court affirmed that probable cause existed under Penal Code §602.1(a) (interfering with a business and refusing to leave).
At trial Turner denied ownership of the firearm, ammo, and methamphetamine and suggested the police planted the items; the court allowed impeachment with evidence that Turner had possessed identical ammunition in an unrelated arrest one month earlier.
Jury convicted Turner of possession of firearm by a felon, possession of ammunition by a felon, and misdemeanor possession of methamphetamine; court imposed three years’ probation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether arrest had probable cause such that an inventory search of the duffel bag was lawful	People: Officer Niemi had probable cause to arrest under Penal Code §602.1(a) based on repeated refusals to leave, manager’s disruption and prior calls about Turner	Turner: Arrest lacked probable cause; mere refusal to leave (and requests to locate phone) did not show intent to interfere with business	Held: Probable cause supported arrest under §602.1(a); inventory search exception applies, so seized evidence was admissible
Whether evidence of prior possession of identical ammunition was admissible to impeach Turner’s testimony that items were not his and/or were planted	People: Prior possession of same ammo is relevant impeachment when Turner suggested police planted evidence	Turner: Prior arrest/possession evidence is prejudicial, and arrests (not convictions) should not be used to impeach; evidence did not directly contradict his narrow denial	Held: Trial court did not abuse discretion—prior possession was admissible to impeach specific testimony and was not unduly prejudicial under Evid. Code §352

Illinois v. Lafayette, 462 U.S. 640 (1983) (inventory searches incident to arrest are a Fourth Amendment exception)
Maryland v. Pringle, 540 U.S. 366 (2003) (practical, totality-of-the-circumstances standard for probable cause)
People v. Kraft, 23 Cal.4th 978 (2000) (probable cause standard for arrests)
People v. Macabeo, 1 Cal.5th 1206 (2016) (search-and-seizure reasonableness principles)
Millwee v. People (People v. Millwee), 18 Cal.4th 96 (1998) (prior similar testimony/acts admissible to impeach by showing implausibility of defense)
People v. Doolin, 45 Cal.4th 390 (2009) (§352 exclusion standard and undue prejudice explanation)
Dubner v. City & County of San Francisco, 266 F.3d 959 (9th Cir. 2001) (refusal-to-leave alone insufficient for §602.1(a) probable cause in civil-rights context)
Chapman v. California, 386 U.S. 18 (1967) (harmless error standard for constitutional error)