What is the legal test for a criminal defendant to obtain copies of a police officer's personnel records from the California Police Service?

Although police officer personnel records are generally confidential, a criminal defendant is entitled to discover the content of such records if the information contained in the records is relevant to his ability to obtain a fair trial or to defend against pending charges. (Pitchess v. Superior Court, supra, 11 Cal.3d at pp. 536-538.) The process by

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which a criminal defendant may discover personnel records is codified in Evidence Code sections 1043 to 1045. Initially, the defendant must submit a motion accompanied by an affidavit or declaration "showing good cause for the discovery or disclosure sought" and "setting forth the materiality thereof to the subject matter involved in the pending litigation." (Evid. Code, 1043, subd. (b)(3).) "To show good cause as required by [Evidence Code] section 1043, [the] declaration in support of a Pitchess motion must propose a defense or defenses to the pending charges" and "articulate how the discovery sought may lead to relevant evidence or may itself be admissible direct or impeachment evidence [citations] that would support those proposed defenses." (Warrick v. Superior Court, supra, 35 Cal.4th at p. 1024.) The declaration "must also describe a factual scenario supporting the claimed officer misconduct." (Ibid.)