What is the test for in-camera review?

California, United States of America


The following excerpt is from People v. Leon, 2d Crim. No. B253707 (Cal. App. 2015):

Appellant contends that the trial court erred by denying his Pitchess motion. We review for abuse of discretion. (Alford v. Superior Court (2003) 29 Cal.4th 1033, 1039.) As we shall explain, in order to grant the in camera review, the trial court would have had to engage in "the willing suspension of disbelief." By any measure, appellant's purported alternative scenario asks this court to apply not the "relaxed standards" required for a showing of good cause, but collapsed standards or no standards at all. We decline the invitation. Appellant's contention that 11 police officers engaged in the premeditated and ad hoc calumny attributed to them defies reason and logic. His claim also ignores the 911 call that summoned them, the confrontation and fire that ensued, and the response of firefighters to the scene. His is not a plausible scenario.

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