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Name: People v. Young
Case #: A143082
Court: CA Court of Appeal
District 1 DCA
Division: 2
Opinion Date: 05/26/2016

Warrantless search of defendant was proper, even though he had already completed more than one year on postrelease community supervision (PRCS), because probation had an additional 30 days in which to discharge him from supervision. On May 14, 2012, Young was released from prison and placed on PRCS. While on supervision he was subject to warrantless searches and prohibited from possessing pornography. Almost a year later, police contacted his probation officer, asking to search his home under the terms of his PRCS, because they had information he was chatting online with teenage girls about sexual matters. In his home, police found child pornography. By the time of the search, one year and one day had passed since Young was placed on PRCS. With criminal charges pending (Pen. Code, § 311.11, subd. (b)), he claimed the search was illegal because his PRCS terminated the day before it occurred. His motion to suppress evidence was denied. He entered a plea, then appealed. Held: Affirmed. The Postrelease Community Supervision Act of 2011 (Pen. Code, § 3450 et seq.) was enacted to “improve public safety outcomes” and to facilitate certain low-level offenders’ reentry into society by providing county supervision of released prison inmates. PRCS terminates upon one of the following events: (1) after three years on PRCS, the person is immediately discharged from supervision; (2) after six months on PRCS with no violations resulting in custodial sanctions, the person may be considered for immediate discharge; or (3) after one year on PRCS with no violations resulting in custody, the person shall be discharged within 30 days (Pen. Code, § 3456, subd. (a)). Based on the plain language of the statute, after a person successfully completes one year of PRCS the supervision agency “shall” discharge him within 30 days. Until that discharge occurs, however, the defendant remains subject to the terms of his release.

The full opinion is available on the court’s website here: