in-camera hearing in California

2025J.T. requests that we independently review the in-camera hearing and sealed personnel records of Deputy Sanchez to determine whether the trial court failed to disclose all relevant and discoverable information contained within the files pursuant to Brady v. Maryland, supra, 373 U.S. 83 , and Pitchess v. Superior Court, supra, 11 Cal.3d 531 .

2022If this court concludes that dismissal is not warranted, this court should review the sealed record of the in- camera hearing on defendant’s Pitchess motion for any further error. 1 Pitchess v. Superior Court (1974) 11 Cal.3d 531 (Pitchess). 2 FACTUAL AND PROCEDURAL HISTORY 2 A. SUMMARY OF FACTS AND CONVICTION As we set forth in the Opinion, Jose Sanchez was sitting in his car at the Stater Brothers shopping center in Loma Linda in the afternoon on February 17, 2017, waiting for his wife, Stacie Garcia.

2025J.T. requests that we independently review the in-camera hearing and sealed personnel records of Deputy Sanchez to determine whether the trial court failed to disclose all relevant and discoverable information contained within the files pursuant to Brady v. Maryland, supra, 373 U.S. 83 , and Pitchess v. Superior Court, supra, 11 Cal.3d 531 .

2025J.T. requests that we independently review the in-camera hearing and sealed personnel records of Deputy Sanchez to determine whether the trial court failed to disclose all relevant and discoverable information contained within the files pursuant to Brady v. Maryland, supra, 373 U.S. 83 , and Pitchess v. Superior Court, supra, 11 Cal.3d 531 .

2018Moreover, those choosing to apply may be less forthright in their responses." ( Cal. First , supra , 67 Cal.App.4th at p. 172 , 78 Cal.Rptr.2d 847 .) In Cal. First , this court reiterated that "an in-camera hearing is not always necessary to resolve the weighing process required by section 6255.

2018Moreover, those choosing to apply may be less forthright in their responses." ( Cal. First , supra , 67 Cal.App.4th at p. 172 , 78 Cal.Rptr.2d 847 .) In Cal. First , this court reiterated that "an in-camera hearing is not always necessary to resolve the weighing process required by section 6255.

2026He also requests this court independently review the sealed transcript of an in-camera hearing and related materials to determine whether any discoverable material was improperly withheld from the defense. 1 All further statutory references are to the Penal Code. 2 People v. Superior Court (Romero) (1996) 13 Cal.4th 497 (Romero). 2 For the reasons below, the court did not err by denying defendant’s Romero motion and declining to strike his prior strike conviction.

2026(People v. Ayala (2000) 23 Cal.4th 225, 299 .) “[W]e independently review whether a Brady violation occurred, giving great weight to the trial court’s findings of fact if they are supported by substantial evidence.” (Deleoz, supra, 80 Cal.App.5th at pp. 656-657.) A violation of California’s reciprocal discovery statute “constitutes reversible error only where it is reasonably probable, by state law standards, that the omission affected the trial result.” (Id. at p. 658.) We have independently reviewed the sealed transcript of the in-camera hearing on October 11, 2023 as well as the sealed decl

2026(People v. Ayala (2000) 23 Cal.4th 225, 299 .) “[W]e independently review whether a Brady violation occurred, giving great weight to the trial court’s findings of fact if they are supported by substantial evidence.” (Deleoz, supra, 80 Cal.App.5th at pp. 656-657.) A violation of California’s reciprocal discovery statute “constitutes reversible error only where it is reasonably probable, by state law standards, that the omission affected the trial result.” (Id. at p. 658.) We have independently reviewed the sealed transcript of the in-camera hearing on October 11, 2023 as well as the sealed decl

2025(People v. Nuno (2024) 105 Cal.App.5th 1030 , 1055; People v. Yearwood (2013) 213 Cal.App.4th 161, 180 [decision will be reversed only on a showing of abuse of discretion].) Our review of the sealed transcript of the in-camera hearing reveals that the trial court did not abuse its discretion during its review of matters within Sanchez’s personnel file.

2025(Warrick v. Superior Court (2005) 35 Cal.4th 1011, 1019 .) Where the defendant has shown good cause, the trial court holds an in-camera hearing to determine whether the evidence should be disclosed to the defense.

2024On appeal, Torrez asks us to “conduct an independent review of the Pitchess hearings and records produced, if any, to determine whether error occurred.” “A motion for discovery of peace officer personnel records is ‘addressed solely to the sound discretion of the trial court.’ [Citation.] A review of the lower court’s ruling is subject to an abuse of discretion standard.” 14 The court also stated that if it were found that the sentence for count 3 should not be stayed, then its intention was to impose the sentence for count 3 to run concurrently, and to strike the firearm enhancement in the in

2023We routinely grant such requests “ ‘to determine whether the trial court 3 abused its discretion in denying a defendant’s motion for disclosure of police personnel records.’ ” (People v. Myles (2012) 53 Cal.4th 1181, 1209 (Myles), quoting People v. Prince (2007) 40 Cal.4th 1179, 1285 .) As Williams correctly notes, our Supreme Court in People v. Mooc (2001) 26 Cal.4th 1216, 1229 , held that a custodian of records appearing at a Pitchess hearing “should be prepared to state in chambers and for the record what other documents (or category of documents) not presented to the court were included in

2022Moreover, Zamora was based on People v. Hitch (1974) 12 Cal.3d 641 ,4 which was overruled by Trombetta, supra, 467 U.S. 479 .

2022Moreover, Zamora was based on People v. Hitch (1974) 12 Cal.3d 641 ,4 which was overruled by Trombetta, supra, 467 U.S. 479 .

2022Moreover, Zamora was based on People v. Hitch (1974) 12 Cal.3d 641 ,4 which was overruled by Trombetta, supra, 467 U.S. 479 .

2021On appeal, defendant contends: (1) we must independently review the sealed transcript of the in-camera hearing pursuant to Pitchess v. Superior Court (1974) 11 Cal.3d 531 to determine whether the trial court abused its discretion in refusing to disclose any potentially relevant personnel records of three police officers; (2) the trial court erred in denying his claim that the prosecutor impermissibly relied on race during jury selection in violation of Batson v. Kentucky (1986) 476 U.S. 79 [ 90 L.Ed.2d 69 ] (Batson); and (3) the trial court abused its discretion in admitting photographs he all

2021On appeal, defendant contends: (1) we must independently review the sealed transcript of the in-camera hearing pursuant to Pitchess v. Superior Court (1974) 11 Cal.3d 531 to determine whether the trial court abused its discretion in refusing to disclose any potentially relevant personnel records of three police officers; (2) the trial court erred in denying his claim that the prosecutor impermissibly relied on race during jury selection in violation of Batson v. Kentucky (1986) 476 U.S. 79 [ 90 L.Ed.2d 69 ] (Batson); and (3) the trial court abused its discretion in admitting photographs he all

2021The Attorney General does not oppose this request. 13 “When a defendant shows good cause for the discovery of information in an officer’s personnel records, the trial court must examine the records in camera to determine if any information should be disclosed.” (People v. Winbush, supra, 2 Cal.5th at p. 424 .) At an in-camera Pitchess hearing, “[t]he trial court should . . . make a record of what documents it examined before ruling on the Pitchess motion. . . . [T]he court can . . . state for the record what documents it examined.” (People v. Mooc (2001) 26 Cal.4th 1216, 1229 .) An appellate c

2021Analysis Defendant asserts the court “erred in limiting the scope of in camera review to ‘false report writing and perjury – refusing to include reports of bias or dishonesty as requested in the motion.” The Attorney General asserts that defendant’s position is based on a misreading of the record, because “[n]othing in the record indicates the trial court limited its review of the detective’s personnel file in any way.” “Pitchess rulings are reviewed for abuse of discretion.” (People v. Winbush (2017) 2 Cal.5th 402, 424 .) We agree defendant’s contention is not supported by the record.

2013“Trial courts are granted wide discretion when ruling on motions to discover police officer personnel records. [Citation.]” (People v. Samayoa (1997) 15 Cal.4th 795, 827 .) “To obtain relief, . . . a defendant who has established that the trial court erred in denying Pitchess discovery must also demonstrate a reasonable probability of a different outcome had the evidence been disclosed. [Citations.]” (People v. Gaines (2009) 46 Cal.4th 172 , 182–183.) We have reviewed the sealed in-camera Pitchess hearing transcript.6 Although the personnel records are not before us, the trial court set forth

1987The court stated that “[t]o allow public knowledge of the location of the secret identification number would destroy its very purpose and would remove a valuable investigatory device that may lead to the discovery of vehicle thefts.” (In re David W, supra, 62 Cal.App.3d at p. 847 .) The court further held that an in-camera hearing was not necessary because the trial court had conducted the very kind of examination that the defendant’s counsel had sought to make to ascertain whether the police witness had correctly reported the VIN, “and satisfied itself that no further examination would, or co

1982The United States Supreme Court stated: “Insofar as the accused’s conviction may rest on a courtroom identification in fact the fruit of a suspect pretrial identification which the accused is helpless to subject to effective scrutiny at trial, the accused is deprived of that right of cross-examination which is an essential safeguard to his right to confront the witnesses against him .Pointer v. Texas, 380 U.S. 400 [ 85 S.Ct. 1065 , 13 L.Ed.2d 925 ].

1982The United States Supreme Court stated: “Insofar as the accused’s conviction may rest on a courtroom identification in fact the fruit of a suspect pretrial identification which the accused is helpless to subject to effective scrutiny at trial, the accused is deprived of that right of cross-examination which is an essential safeguard to his right to confront the witnesses against him .Pointer v. Texas, 380 U.S. 400 [ 85 S.Ct. 1065 , 13 L.Ed.2d 925 ].