What is the record of a trial court's review of discovery of material contained in law enforcement personnel files?

California, United States of America


The following excerpt is from The People v. Ramirez, B220114, No. BA351115 (Cal. App. 2011):

A trial court's decision concerning the discovery of material contained in law enforcement personnel files is, in most instances, reviewed for abuse of discretion. (People v. Mooc (2001) 26 Cal.4th 1216, 1228.) We have reviewed the transcript of the June 9, 2009 in camera hearing, and we have determined that it constitutes an adequate record of the trial court's review of the documents provided to the court. We conclude that the trial court clearly did not abuse its discretion by failing to disclose discoverable information from the deputy's personnel files. (See id. at pp. 1228-1230, 1232.)

The judgment is affirmed.

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