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Name: People v. Adams
Case #: H024504
Court: CA Court of Appeal
District 6 DCA
Opinion Date: 01/27/2004
Subsequent History: 2/5/04: opn modified without chg in jmt; Rev. den. 4/14/04

The trial court properly excluded third-party culpability evidence and properly admitted DNA testing results even though the DNA was obtained without reasonable suspicion or a warrant. After DNA evidence obtained in 2001 connected the defendant to a twenty-year-old murder case, he was convicted by a jury of murder with special circumstances. In affirming his conviction, the court of appeal held that the trial court did not abuse its discretion in excluding third party culpability evidence, where much of the evidence was irrelevant and cumulative of other evidence that could have linked a third party to the crime. Next, the court held that the seizure of the defendant’s blood while he was a state prisoner did not violate the Fourth Amendment and did not require reasonable suspicion or a warrant. The court further rejected the defendant’s arguments that the jury should have been instructed that the felony-murder special circumstance required a specific intent to kill, and that retroactive application of People v. Anderson (1987) 43 Cal.3d 1104 to his case violated the ex posto facto and due process clauses of the Federal Constitution. Finally, the court held that the defendant was statutorily ineligible for presentence credits under Penal Code section 4019 due to his sentence of life without the possibility of parole.