What is the test for in camera review of a confidential file?

California, United States of America


The following excerpt is from People v. Barrios, E069418 (Cal. App. 2019):

The defendant's right to a fair trial and the state's interest in confidentiality of files can be properly accommodated through the trial court's in camera review of the files. (J.E., supra, 223 Cal.App.4th at p. 1336; Pennsylvania v. Ritchie (1987) 480 U.S. 39, 59-61.) The defendant must make a threshold showing of materiality to trigger the trial court's duty to search the file. (J.E., supra, at p. 1336; Pennsylvania v. Ritchie, supra, at p. 58, fn. 15 [petitioner "may not require the trial court to search through the . . . [confidential] file without first establishing a basis for his claim that it contains

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