California, United States of America
The following excerpt is from People v. Strickland, F073505 (Cal. App. 2018):
A trial court's ruling on a motion to quash a subpoena duces tecum is reviewed for abuse of discretion. (See, e.g., People v. York (1980) 108 Cal.App.3d 779, 792; see also People v. Ayala (2000) 23 Cal.4th 225, 299 ["We generally review a trial court's ruling
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on matters regarding discovery under an abuse of discretion standard."].) "Under the abuse of discretion standard, 'a trial court's ruling will not be disturbed, and reversal of the judgment is not required, unless the trial court exercised its discretion in an arbitrary, capricious, or patently absurd manner that resulted in a manifest miscarriage of justice.' [Citation.]" (People v. Hovarter (2008) 44 Cal.4th 983, 1004; see People v. Kipp (1998) 18 Cal.4th 349, 371 ["A court abuses its discretion when its ruling 'falls outside the bounds of reason.' "].)
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