Is a court's decision on discoverability of material in a police personnel file reviewable under the abuse standard?

California, United States of America


The following excerpt is from People v. Galan, 100 Cal. Rptr. 3d 103, 178 Cal.App.4th 6 (Cal. App. 2009):

"A trial court's decision on the discoverability of material in police personnel files is reviewable under an abuse of discretion standard. [Citation.]" (People v. Jackson (1996) 13 Cal.4th 1164, 1220-1221 [56 Cal.Rptr.2d 49, 920 P.2d 1254].) "A trial court abuses its discretion when its ruling `fall[s] "outside the bounds of reason."' [Citation.]" (People v. Waidla (2000) 22 Cal.4th 690, 714 [94 Cal.Rptr.2d 396, 996 P.2d 46].)

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