What is the test for abuse of discretion on a motion for disclosure of in camera proceedings?

California, United States of America


The following excerpt is from People v. Soberanis, B243922 (Cal. App. 2014):

We review the trial court's determination for an abuse of discretion. (People v. Jackson (1996) 13 Cal.4th 1164, 1220-1221.) We have reviewed the sealed record of the

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in camera proceedings and have determined that the custodian of the records was duly sworn. We find the transcript sufficiently detailed to review the trial court's discretion, as the court orally described for the record each document produced. (See People v. Mooc (2001) 26 Cal.4th 1216, 1228-1229.) Upon review of the sealed transcript, we conclude that the trial court properly exercised its discretion in determining that no documents existed within the scope of the Pitchess motion, and that no documents or information should be disclosed to the defense as a result of the review.

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