How has the court interpreted Pitchess on a motion to compel disclosure of a law enforcement officer's personnel file?

"Pitchess, supra, 11 Cal.3d 531, and its statutory progeny are based on the premise that evidence contained in a law enforcement officer's personnel file may be relevant to an accused's criminal defense and that to withhold such relevant evidence from the defendant would violate the accused's due process right to a fair trial. Pitchess and Evidence Code sections 1043 through 1047 also recognize that the officer in question has a strong privacy interest in his or her personnel records and that such records should not be disclosed unnecessarily. Accordingly, both Pitchess and the statutory scheme codifying Pitchess require the intervention of a neutral trial judge, who examines the personnel records in camera, away from the eyes of either party, and orders disclosed to the defendant only those records that are found both relevant and otherwise in compliance with statutory limitations." (People v. Mooc (2001) 26 Cal.4th 1216, 1227.)

We have reviewed the sealed reporter's transcript of the in camera Pitchess proceedings. Our review of the record reflects the trial court did not abuse its discretion in concluding there were no more discoverable materials than those ordered disclosed by the trial court. (See People v. Hughes (2002) 27 Cal.4th 287, 330 [a ruling on a Pitchess motion is reviewed for an abuse of discretion].) Additionally, our review of the sealed transcript reveals no error in the trial court's narrowing of the subpoena duces tecum. In sum, the trial court did not err.