What is the standard of review in the context of an investigation into the handling of evidence by the Police and the Prosecutor?

California, United States of America


The following excerpt is from People v. Castaneda, B261363 (Cal. App. 2016):

Third, while it is plain that People's investigation was not a model of efficiency and diligence, there was, as the trial court found, no evidence of bad faith conduct by the police or the prosecutor. A trial court's inquiry into whether the People's handling of evidence was done in good faith or bad faith is essentially a factual inquiry and, as such, the proper standard of review is substantial evidence. (See People v. Memro (1995) 11 Cal.4th 786, 831, overruled on a different point in People v. Gaines (2009) 46 Cal.4th 172, 181, fn. 2.) Substantial evidence is evidence that is "reasonable, credible, and of solid value." (People v. Rodriguez (1999) 20 Cal.4th 1, 11.) "'"'"If the circumstances reasonably justify the trier of fact's findings, the opinion of the reviewing court that the circumstances might also reasonably be reconciled with a contrary finding does not warrant a reversal of the judgment."'"'" (Ibid.)

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