What is the test for an abuse of discretion determination that no documents or information should be disclosed to the defense as a result of a review of in camera proceedings?

California, United States of America


The following excerpt is from People v. Joseph, B246703 (Cal. App. 2014):

The trial court's determination is reviewed for an abuse of discretion. (People v. Jackson (1996) 13 Cal.4th 1164, 1220-1221.) We have considered the sealed record of the in camera proceedings and although the trial court did not keep a copy of the personnel records, we find the transcript sufficiently detailed to review the trial court's discretion, as the trial court orally described for the record each document produced. (See People v. Mooc (2001) 26 Cal.4th 1216, 1228-1229.) Upon review of the sealed transcript, we conclude that the trial court properly exercised its discretion in determining that no documents existed within the scope of the Pitchess motion as granted by the court, and that no documents or information should be disclosed to the defense as a result of the review.

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