The Second Appellate District affirmed a judgment. The court held that a Proposition 36 probationer’s use of a device to falsify a urine test result so as to avoid detection of his drug use was not “drug-related” conduct for purposes of continued eligibility for Prop 36 probation.

Ousama Haddad pleaded guilty to possessing and being under the influence of controlled substances. He was placed on Prop 36 probation. One of the conditions of Haddad’s probation was that he submit to periodic drug testing.