What is the test for abuse of discretion in a motion for access to police records?

California, United States of America


The following excerpt is from In Re A.A., B223715, Los Angeles County Super. Ct. No. JJ17281 (Cal. App. 2010):

We review the juvenile court's ruling on the Pitchess motion for abuse of discretion. (People v. Prince (2007) 40 Cal.4th 1179, 1286; see also People v. Hughes (2002) 27 Cal.4th 287, 330 [A trial court's ruling on a motion for access to law enforcement personnel records is subject to review for abuse of discretion].)

"Evidence Code sections 1043 through 1045 codify Pitchess v. Superior Court (1974) 11 Cal.3d 531 [113 Cal.Rptr. 897, 522 P.2d 305]. 'The statutory scheme carefully balances two directly conflicting interests: the peace officer's just claim to confidentiality, and the criminal defendant's equally compelling interest in all

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