What is the test for discovery of a police officer's personnel file?

California, United States of America


The following excerpt is from People v. Gallardo, G045875 (Cal. App. 2013):

The Evidence Code provides a limited right to discovery of an officer's personnel file maintained pursuant to Penal Code section 832.5. The accused is entitled to discover relevant information or documents in the officer's personnel file on a showing of good cause. (People v. Gaines (2009) 46 Cal.4th 172, 176; Evid. Code, 1043, subd. (b)(1).) In order to establish good cause, the defense must submit an affidavit in support

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