In what circumstances have we rejected a motion for disclosure of complaints in a police officer's personnel file relating to fabrication of evidence?

For similar reasons, we reject Serna's constitutional argument that he was prevented from presenting a defense. (People v. Cunningham (2001) 25 Cal.4th 926, 999 ["Although the complete exclusion of evidence intended to establish an accused's defense may impair his or her right to due process of law, the exclusion of defense evidence on a minor or subsidiary point does not interfere with that constitutional right."].)

Serna filed a pretrial Pitchess motion for disclosure of complaints in Officer Duran's personnel file pertaining to fabrication of evidence, false arrest, perjury, dishonesty, false police reports, false or misleading internal reports, and "any other evidence of misconduct amounting to moral turpitude within the meaning of People v. Wheeler (1992) 4 Cal.4th 284 [(Wheeler)]." The motion rested on Serna's attack on Officer Duran's veracity. Specifically, Serna argued Officer Duran falsely stated in a police report that Serna said while in custody that he had bought the phone from his friend "Dominic."

Page 9