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

California, United States of America


The following excerpt is from People v. Pedroza, B296685 (Cal. App. 2020):

We review the trial court's determination for an abuse of discretion. (People v. Jackson (1996) 13 Cal.4th 1164, 1220-1221.) The personnel records produced in the in camera hearing were not retained, but the custodian of the record was sworn, and the trial court examined and described each document produced. We have reviewed the sealed transcript of that hearing and find the court's descriptions sufficient for review of the trial court's determination, without having to order production of the same documents in this court. (See People v. Mooc (2001) 26 Cal.4th 1216, 1228-1229.) Upon review of the sealed record, we conclude the trial court properly exercised its discretion in determining that the documents produced complied with the scope of the Pitchess motion, and that none of the documents or information contained facts relating to perjury or dishonesty or relevant to defendant's case, and thus were not to be disclosed to the defense.

The judgment is affirmed.

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