What is the test for discovery of a law enforcement officer's personnel records?

California, United States of America


The following excerpt is from People v. Ellis, F066893 (Cal. App. 2015):

Second, if the trial court finds good cause for discovery of the personnel records, the court conducts an in camera review of the pertinent documents to determine which, if any, are relevant to the case. (Warrick v. Superior Court (2005) 35 Cal.4th 1011, 1019.) The court "discloses only that information falling within the statutorily defined standards of relevance." (Ibid.)

Absent a showing of good cause, a law enforcement officer's personnel records are not relevant to any issue in the case. (People v. Collins (2004) 115 Cal.App.4th 137,

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