What are the findings of an in camera review of a police officer's personnel file?

California, United States of America


The following excerpt is from People v. Ellington, B289935 (Cal. App. 2019):

Detective Salas's personnel file, the trial court concluded there were no discoverable records. Defendant contends, and the Attorney General agrees, we should conduct an independent in camera review of the sealed record. We have independently reviewed the transcript of the in camera proceeding and, based on the trial court's description of the contents of the personnel file, conclude the trial court did not abuse its discretion in finding there were no discoverable documents. (People v. Hughes (2002) 27 Cal.4th 287, 330.)

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