This is a for a 2015 case.
Officers saw a vehicle rolling backwards without lights. Parrott exited from the driver’s side and pushed the car to the curb. The officers approached, offering assistance as Parrott began to lift the hood. Parrott said he did not need help. The officers noticed that Parrot was nervous and kept touching a large item bulging from the front pocket of his sweatshirt. While questioning Parrott, the officers learned that his drivers’ license was suspended.
A pat-down search revealed a loaded gun in the sweatshirt pocket. After his motion to suppress was denied, Parrott pled guilty to two charges of being a felon in possession of a firearm (Pen. Code 29800(a)), and admitted to two sentencing enhancements. He was sentenced to five years in state prison. The court of appeal affirmed, rejecting arguments that Parrott’s Fourth Amendment rights were violated by an unlawful search and seizure resulting in the discovery of one of the firearms and that he was deprived of his Sixth Amendment right to counsel at sentencing. While the record does not establish Parrot properly waived his right to counsel and unequivocally invoked his right to self-representation, the error was harmless beyond a reasonable doubt.