In People v. Buza (2014) 231 Cal.App.4th 1446, the court addressed "the constitutionality of a provision of the Act, which requires that a DNA sample be taken from all adults arrested for or charged with any felony offense 'immediately following arrest, or during the booking . . . process or as soon as administratively practicable after arrest . . . .' " (Id. at pp. 1450-1451.) The Buza court vigorously criticized the Supreme Court's decision in Maryland v. King, but made clear that it based its decision "solely upon article I, section 13, of the California Constitution, which in its view undoubtedly prohibited the search and seizure at issue." (People v. Buza, supra, 231 Cal.App.4th at pp. 1451, 1459-1465.) The defendant in People v. Buza, supra, 231 Cal.App.4th 1446 was arrested for setting fire to a police car in January 2009. A few hours after his arrest, he was asked to provide a DNA sample and refused, even though he was told that his refusal would constitute a misdemeanor. (Id. at pp. 1451-1452.) Ultimately, the defendant was found guilty of refusing to provide a DNA sample ( 298.1, subd. (a)), in addition to arson, vandalism, and possession of combustible material. (People v. Buza, supra, 231 Cal.App.4th at pp. 1452-1453.) On appeal, the defendant in People v. Buza did "not challenge the . . . Act in all its applications--such as its requirement of postconviction DNA testing." (People v. Buza, supra, 231 Cal.App.4th at p. 1467, fn. 7.) Rather, the defendant challenged "only the specific search demanded of him, after his arrest and before he was formally charged." (Ibid.) The court observed that "the scope of permissible searches of arrestees is one of the specific areas in which article I, section 13, of the California Constitution has been held to provide greater protection than the Fourth Amendment. " (People v. Buza, supra, 231 Cal.App.4th at p. 1480.) Greater protection notwithstanding, "since the adoption of Proposition 8, evidence cannot be excluded as violative of state protections against unreasonable search and seizure unless it would also be inadmissible under the Fourth Amendment. " (People v. Buza, supra, 231 Cal.App.4th at p. 1483.) The Buza court further stated: "It would be surprising to find California cases decided after Proposition 8 discussing differences in the substantive scope of the state and federal search and seizure provisions, as it is highly unusual for search and seizure issues to arise in any context other than a suppression motion, which Proposition 8 requires to be decided according to federal law. The unavailability of the exclusionary rule as a remedy for violations of the state Constitution that are not violations of the Fourth Amendment means that state courts considering suppression of evidence must engage in a Fourth Amendment analysis. " (People v. Buza, supra, 231 Cal.App.4th at p. 1485.) The court reiterated that the case before it had "nothing to do with the exclusionary rule," stating: "The question here is not whether an illegal search and seizure requires suppression of evidence at trial but whether the state can criminalize the refusal to comply with a search that would violate the state's proscription against unreasonable searches." (Id. at pp. 1485-1486.)