Can an informant be deemed to be material to the issue of guilt in a criminal case?

An informant may not be material to the issue of guilt where he is determined to be material to the issue of probable cause underlying the [157 Cal.App.3d 461] issuance of a search warrant. (People v. Hardeman (1982) 137 Cal.App.3d 823, 830-831, 187 Cal.Rptr. 296.) In People v. Galante (1983) 143 Cal.App.3d 709, 192 Cal.Rptr. 184, an informant had made purchases of cocaine at the premises where defendant resided. That informant served as the basis of the search warrant. During the search, cocaine was found in a locked file cabinet in defendant's bedroom. The key to the cabinet was found in the defendant's trousers. In holding that the trial court properly denied the defendant's motion for informant disclosure, the court reasoned that since the informant had not indicated knowledge of the defendant's possession of cocaine in the locked box, his testimony could not exonerate the defendant.