Does the doctrine of correcting errors postjudgment apply to a motion to suppress evidence?

California, United States of America


The following excerpt is from People v. Ivan T., 90 Cal.Rptr.2d 588 (Cal. App. 1999):

In People v. Ramirez (1992) 6 Cal.App.4th 1583, the court erroneously applied an incorrect legal standard when ruling on a motion to suppress evidence. The trial court, realizing its error, reconsidered the motion and changed its ruling. The appellate court concluded "a trial court should be allowed to reconsider a motion to suppress evidence before the commencement of trial when it has applied an incorrect legal standard in making its ruling. Such a holding is consistent with the notions of judicial economy . . . as well as a trial court's statutory powers to modify its orders . . . ." (Id. at pp. 1592-1593, fn. omitted.) In making its decision, the court "acknowledge[d] a line of authority holding errors in the exercise of judicial discretion, or judicial errors, 'noncorrectible.' [Citation.]" (Id. at p. 1593, fn. 6.) However, the court stated that "this doctrine has been largely applied to prohibit the correction of errors postjudgment. [Citations.] Furthermore, most cases relying on the doctrine have prevented reconsideration of the factual bases for rulings greatly affecting the rights or status of a party. [Citation.]" (Ibid., italics in original.)

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