What is the test for disclosing information in camera in a civil case?

California, United States of America


The following excerpt is from People v. Rivera, 247 Cal.Rptr.3d 363, 441 P.3d 359, 7 Cal.5th 306 (Cal. 2019):

"When a defendant shows good cause for the discovery of information in an officers personnel records, the trial court must examine the records in camera to determine if any information should be disclosed. [Citation.] The court may not disclose complaints over five years old, conclusions drawn during an investigation, or facts so remote or irrelevant that their disclosure would be of little benefit. [Citations.] Pitchess rulings are reviewed for abuse of discretion." ( People v. Winbush (2017) 2 Cal.5th 402, 424, 213 Cal.Rptr.3d 1, 387 P.3d 1187.)

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