Under what circumstances can a defendant seek discovery of a police officer's in-camera records?

Under Pitchess, supra, 11 Cal.3d at pages 537-538, and Evidence Code sections 1043 and 1045, a defendant may file a motion for discovery of certain personnel records concerning police officers, when those records are material to the defense of a pending criminal prosecution. Upon a proper showing of good cause by the defendant, the court is required to review the personnel records in camera and order disclosure of appropriate records. (See People v. Mooc (2001) 26 Cal.4th 1216, 1219-1220.) Here, the court conducted that review and did not order disclosure of any records to Ledesma or his codefendant. The court, as required, ordered the record of its in camera review, and the records themselves, sealed.

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