What are the requirements of a court for in camera review of a law enforcement officer's personnel file?

California, United States of America


The following excerpt is from People v. Kay, D073187 (Cal. App. 2018):

"When a trial court concludes a defendant's Pitchess motion shows good cause for discovery of relevant evidence contained in a law enforcement officer's personnel files, the custodian of the records is obligated to bring to the trial court all 'potentially relevant' documents to permit the trial court to examine them for itself." (People v. Mooc (2001) 26 Cal.4th 1216, 1228-1229 (Mooc).) "Documents clearly irrelevant to a defendant's Pitchess request need not be presented to the trial court for in camera review. But if the custodian has any doubt whether a particular document is relevant, he or she should present it to the trial court." (Id. at p. 1229.) "The custodian should be prepared to state in chambers and for the record what other documents (or category of documents) not

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