When will a court review in camera review of potentially discoverable information from an officer's personnel file?

California, United States of America


The following excerpt is from People v. Dorado, 2d Crim. No. B256428 (Cal. App. 2015):

When the trial court conducts an in camera review of potentially discoverable information from an officer's personnel files, it must "make a record of what documents it examined before ruling on the Pitchess motion." (People v. Mooc (2001) 26 Cal.4th 1216, 1229.) The ruling will be upheld absent an abuse of discretion. (Id. at p. 1228.) We have independently reviewed the sealed reporter's transcript of the in camera hearing. The record is sufficient to permit appellate review, and we conclude the trial court properly exercised its discretion in denying discovery.

The judgment is affirmed.

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