California, United States of America
The following excerpt is from People v. Ayala, 1 P.3d 3, 23 Cal.4th 225, 96 Cal.Rptr.2d 682 (Cal. 2000):
"We review for abuse of discretion a trial court's ruling on a motion to reopen a criminal case to permit the introduction of additional evidence." (People v. Marshall, supra, 13 Cal.4th 799, 836, 55 Cal. Rptr.2d 347, 919 P.2d 1280.) We find none here. Nor do we find any prosecutorial misconduct. Defendant could produce no evidence that the prosecution enabled Mendoza and Meza to confer and tailor their testimony, or that of Mendoza, or that Mendoza's testimony was altered as a result of his lodging in the South Bay jail. Nor was defendant denied any right to present a defense, or more precisely, evidence relevant to the theory of his defense. Such a right does not require "the court [to] allow an unlimited inquiry into collateral matters," which this surely was; rather, "the proffered evidence must have more than slight relevanc[e]." (Ibid.) Finally, because informing defendant of the two men's confinement arrangement would not have created a reasonable probability of a different outcome, we discern no violation of the due process right to be provided with favorable material evidence. Nor do we discern the denial of any right to a reliable guilt and penalty determination.
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