What is the test for establishing good cause for a Pitchess hearing?

California, United States of America


The following excerpt is from People v. Schabeck, C081876 (Cal. App. 2017):

A party seeking disclosure of a police officer's personnel records must show "good cause for the discovery or disclosure sought, setting forth the materiality thereof to the subject matter involved in the pending litigation." (Evid. Code, 1043, subd. (b)(3).) The threshold for establishing good cause to hold a Pitchess hearing is "relatively low." (City of Santa Cruz v. Municipal Court (1989) 49 Cal.3d 74, 83, 84.)

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