What is the test for showing cause for in camera review of a police officer's personnel records?

California, United States of America


The following excerpt is from People v. Vasquez, B241020 (Cal. App. 2014):

Defendant correctly points out that to show cause for an in camera review of an officer's personnel records, he "need demonstrate only 'a logical link between the defense proposed and the pending charge' and describe with some specificity 'how the discovery being sought would support such a defense or how it would impeach the officer's version of events.' [Citation.]" (People v. Gaines (2009) 46 Cal.4th 172, 182.) We review a trial court's ruling on a Pitchess motion under the deferential abuse of discretion standard. (Alford v. Superior Court (2003) 29 Cal.4th 1033, 1039.)

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