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10 California opinions name it 2 courts 2020–2026 8 in the last five years
The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
City of Alhambra v. Superior Courtgreen2 sentences2026The district attorney also argued that application of the factors set forth in City of Alhambra v. Superior Court (1988) 205 Cal.App.3d 1118 (Alhambra)—the Alhambra factors—warranted denying the requested discovery, because Small failed to demonstrate that he had attempted to obtain any relevant information readily available to him through other sources, such as the public defender’s office. 2026The district attorney also argued that application of the factors set forth in City of Alhambra v. Superior Court (1988) 205 Cal.App.3d 1118 (Alhambra)—the Alhambra factors—warranted denying the requested discovery, because Small failed to demonstrate that he had attempted to obtain any relevant information readily available to him through other sources, such as the public defender’s office. | 3 | 7 |
People v. Kaurishgreen2 sentences2020(Alhambra, supra, 205 Cal.App.3d at p. 1134 [discovery context]; see also Facebook (Hunter), supra, 4 Cal.5th at pp. 1289–1290 [regarding asserted burdens on a social media provider]; Serrata, supra, 62 Cal.App.3d 9, 15 ; cf. People v. Kaurish (1990) 52 Cal.3d 648, 686 [criminal discovery may be denied if “the burdens placed on government and on third parties substantially outweigh the demonstrated need”].) For convenience, we will refer to these seven considerations as the “Alhambra factors.” 19 FACEBOOK, INC. v. SUPERIOR COURT Opinion of the Court by Cantil-Sakauye, C. 2020(Alhambra, supra, 205 Cal.App.3d at p. 1134 [discovery context]; see also Facebook (Hunter), supra, 4 Cal.5th at pp. 1289–1290 [regarding asserted burdens on a social media provider]; Serrata, supra, 62 Cal.App.3d 9, 15 ; cf. People v. Kaurish (1990) 52 Cal.3d 648, 686 [criminal discovery may be denied if “the burdens placed on government and on third parties substantially outweigh the demonstrated need”].) For convenience, we will refer to these seven considerations as the “Alhambra factors.” 19 FACEBOOK, INC. v. SUPERIOR COURT Opinion of the Court by Cantil-Sakauye, C. | 2 | 2 |
Kling v. Superior Courtgreen2 sentences2020In the process, we include additional relevant case citations to those set forth in Alhambra and Hoffstadt on Criminal Discovery: (1) Has the defendant carried his burden of showing a “ ‘plausible justification’ ” for acquiring documents from a third party (Kling v. Superior Court of Ventura County (2010) 50 Cal.4th 1068, 1075 (Kling); Hill v. Superior Court (1974) 10 Cal.3d 812 , 817–818 (Hill) [discovery context]; Joe Z. v. Superior Court (1970) 3 Cal.3d 797, 804 (Joe Z.) [discovery context]; Ballard v. Superior Court (1966) 64 Cal.2d 159, 167 (Ballard) [discovery context]; see also, e.g., F 2020In the process, we include additional relevant case citations to those set forth in Alhambra and Hoffstadt on Criminal Discovery: (1) Has the defendant carried his burden of showing a “ ‘plausible justification’ ” for acquiring documents from a third party (Kling v. Superior Court of Ventura County (2010) 50 Cal.4th 1068, 1075 (Kling); Hill v. Superior Court (1974) 10 Cal.3d 812 , 817–818 (Hill) [discovery context]; Joe Z. v. Superior Court (1970) 3 Cal.3d 797, 804 (Joe Z.) [discovery context]; Ballard v. Superior Court (1966) 64 Cal.2d 159, 167 (Ballard) [discovery context]; see also, e.g., F | 2 | 2 |
Cabell v. Valerie E.green2 sentences2020In the process, we include additional relevant case citations to those set forth in Alhambra and Hoffstadt on Criminal Discovery: (1) Has the defendant carried his burden of showing a “ ‘plausible justification’ ” for acquiring documents from a third party (Kling v. Superior Court of Ventura County (2010) 50 Cal.4th 1068, 1075 (Kling); Hill v. Superior Court (1974) 10 Cal.3d 812 , 817–818 (Hill) [discovery context]; Joe Z. v. Superior Court (1970) 3 Cal.3d 797, 804 (Joe Z.) [discovery context]; Ballard v. Superior Court (1966) 64 Cal.2d 159, 167 (Ballard) [discovery context]; see also, e.g., F 2020In the process, we include additional relevant case citations to those set forth in Alhambra and Hoffstadt on Criminal Discovery: (1) Has the defendant carried his burden of showing a “ ‘plausible justification’ ” for acquiring documents from a third party (Kling v. Superior Court of Ventura County (2010) 50 Cal.4th 1068, 1075 (Kling); Hill v. Superior Court (1974) 10 Cal.3d 812 , 817–818 (Hill) [discovery context]; Joe Z. v. Superior Court (1970) 3 Cal.3d 797, 804 (Joe Z.) [discovery context]; Ballard v. Superior Court (1966) 64 Cal.2d 159, 167 (Ballard) [discovery context]; see also, e.g., F | 2 | 2 |
JOE Z. v. Superior Courtgreen2 sentences2020In the process, we include additional relevant case citations to those set forth in Alhambra and Hoffstadt on Criminal Discovery: (1) Has the defendant carried his burden of showing a “ ‘plausible justification’ ” for acquiring documents from a third party (Kling v. Superior Court of Ventura County (2010) 50 Cal.4th 1068, 1075 (Kling); Hill v. Superior Court (1974) 10 Cal.3d 812 , 817–818 (Hill) [discovery context]; Joe Z. v. Superior Court (1970) 3 Cal.3d 797, 804 (Joe Z.) [discovery context]; Ballard v. Superior Court (1966) 64 Cal.2d 159, 167 (Ballard) [discovery context]; see also, e.g., F 2020In the process, we include additional relevant case citations to those set forth in Alhambra and Hoffstadt on Criminal Discovery: (1) Has the defendant carried his burden of showing a “ ‘plausible justification’ ” for acquiring documents from a third party (Kling v. Superior Court of Ventura County (2010) 50 Cal.4th 1068, 1075 (Kling); Hill v. Superior Court (1974) 10 Cal.3d 812 , 817–818 (Hill) [discovery context]; Joe Z. v. Superior Court (1970) 3 Cal.3d 797, 804 (Joe Z.) [discovery context]; Ballard v. Superior Court (1966) 64 Cal.2d 159, 167 (Ballard) [discovery context]; see also, e.g., F | 2 | 2 |
Ballard v. Superior Court of San Diego Countyred2 sentences2020In the process, we include additional relevant case citations to those set forth in Alhambra and Hoffstadt on Criminal Discovery: (1) Has the defendant carried his burden of showing a “ ‘plausible justification’ ” for acquiring documents from a third party (Kling v. Superior Court of Ventura County (2010) 50 Cal.4th 1068, 1075 (Kling); Hill v. Superior Court (1974) 10 Cal.3d 812 , 817–818 (Hill) [discovery context]; Joe Z. v. Superior Court (1970) 3 Cal.3d 797, 804 (Joe Z.) [discovery context]; Ballard v. Superior Court (1966) 64 Cal.2d 159, 167 (Ballard) [discovery context]; see also, e.g., F 2020In the process, we include additional relevant case citations to those set forth in Alhambra and Hoffstadt on Criminal Discovery: (1) Has the defendant carried his burden of showing a “ ‘plausible justification’ ” for acquiring documents from a third party (Kling v. Superior Court of Ventura County (2010) 50 Cal.4th 1068, 1075 (Kling); Hill v. Superior Court (1974) 10 Cal.3d 812 , 817–818 (Hill) [discovery context]; Joe Z. v. Superior Court (1970) 3 Cal.3d 797, 804 (Joe Z.) [discovery context]; Ballard v. Superior Court (1966) 64 Cal.2d 159, 167 (Ballard) [discovery context]; see also, e.g., F | 2 | 2 |
Facebook, Inc. v. City of S.F.green2 sentences2026Alhambra factors A party can oppose disclosure under the Alhambra factors “by establishing that, for example, the [party seeking discovery] can obtain the same information by other means, or that the burden on the [party from whom discovery is sought] is not justified under the circumstance.” (Facebook, Inc. v. Superior Court (Hunter) (2018) 4 Cal.5th 1245, 1290 (Hunter).) The district attorney argues that in weighing the Alhambra factors, the trial court abused its discretion by “excusing Small from reviewing readily available information before compelling disclosure.” We disagree. 2026Alhambra factors A party can oppose disclosure under the Alhambra factors “by establishing that, for example, the [party seeking discovery] can obtain the same information by other means, or that the burden on the [party from whom discovery is sought] is not justified under the circumstance.” (Facebook, Inc. v. Superior Court (Hunter) (2018) 4 Cal.5th 1245, 1290 (Hunter).) The district attorney argues that in weighing the Alhambra factors, the trial court abused its discretion by “excusing Small from reviewing readily available information before compelling disclosure.” We disagree. | 1 | 2 |
Askmo v. Askmogreen2 sentences2024Its explanation satisfied Touchstone’s requirement that the court “articulate orally, and have memorialized in the reporter’s transcript, its consideration of the relevant factors.” (Touchstone, 10 Cal.5th at p. 358; see also In re Marriage of Askmo (2000) 85 Cal.App.4th 1032, 1040 [“Code of Civil Procedure section 632 requires the trial court to issue a statement of decision ‘upon the trial of a question of fact’ when it receives a request therefor by a party appearing at trial. 2024Its explanation satisfied Touchstone’s requirement that the court “articulate orally, and have memorialized in the reporter’s transcript, its consideration of the relevant factors.” (Touchstone, 10 Cal.5th at p. 358; see also In re Marriage of Askmo (2000) 85 Cal.App.4th 1032, 1040 [“Code of Civil Procedure section 632 requires the trial court to issue a statement of decision ‘upon the trial of a question of fact’ when it receives a request therefor by a party appearing at trial. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in California. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Hill v. Superior Court
green
2 sentences2020In the process, we include additional relevant case citations to those set forth in Alhambra and Hoffstadt on Criminal Discovery: (1) Has the defendant carried his burden of showing a “ ‘plausible justification’ ” for acquiring documents from a third party (Kling v. Superior Court of Ventura County (2010) 50 Cal.4th 1068, 1075 (Kling); Hill v. Superior Court (1974) 10 Cal.3d 812 , 817–818 (Hill) [discovery context]; Joe Z. v. Superior Court (1970) 3 Cal.3d 797, 804 (Joe Z.) [discovery context]; Ballard v. Superior Court (1966) 64 Cal.2d 159, 167 (Ballard) [discovery context]; see also, e.g., F 2020In the process, we include additional relevant case citations to those set forth in Alhambra and Hoffstadt on Criminal Discovery: (1) Has the defendant carried his burden of showing a “ ‘plausible justification’ ” for acquiring documents from a third party (Kling v. Superior Court of Ventura County (2010) 50 Cal.4th 1068, 1075 (Kling); Hill v. Superior Court (1974) 10 Cal.3d 812 , 817–818 (Hill) [discovery context]; Joe Z. v. Superior Court (1970) 3 Cal.3d 797, 804 (Joe Z.) [discovery context]; Ballard v. Superior Court (1966) 64 Cal.2d 159, 167 (Ballard) [discovery context]; see also, e.g., F | 2 | 2020–2020 |
People v. Serrata
green
2 sentences2020(Alhambra, supra, 205 Cal.App.3d at p. 1134 [discovery context]; see also Facebook (Hunter), supra, 4 Cal.5th at pp. 1289–1290 [regarding asserted burdens on a social media provider]; Serrata, supra, 62 Cal.App.3d 9, 15 ; cf. People v. Kaurish (1990) 52 Cal.3d 648, 686 [criminal discovery may be denied if “the burdens placed on government and on third parties substantially outweigh the demonstrated need”].) For convenience, we will refer to these seven considerations as the “Alhambra factors.” 19 FACEBOOK, INC. v. SUPERIOR COURT Opinion of the Court by Cantil-Sakauye, C. 2020(Alhambra, supra, 205 Cal.App.3d at p. 1134 [discovery context]; see also Facebook (Hunter), supra, 4 Cal.5th at pp. 1289–1290 [regarding asserted burdens on a social media provider]; Serrata, supra, 62 Cal.App.3d 9, 15 ; cf. People v. Kaurish (1990) 52 Cal.3d 648, 686 [criminal discovery may be denied if “the burdens placed on government and on third parties substantially outweigh the demonstrated need”].) For convenience, we will refer to these seven considerations as the “Alhambra factors.” 19 FACEBOOK, INC. v. SUPERIOR COURT Opinion of the Court by Cantil-Sakauye, C. | 2 | 2020–2020 |
Pacific Lighting Leasing Co. v. Superior Court
green
2 sentences2020In the process, we include additional relevant case citations to those set forth in Alhambra and Hoffstadt on Criminal Discovery: (1) Has the defendant carried his burden of showing a “ ‘plausible justification’ ” for acquiring documents from a third party (Kling v. Superior Court of Ventura County (2010) 50 Cal.4th 1068, 1075 (Kling); Hill v. Superior Court (1974) 10 Cal.3d 812 , 817–818 (Hill) [discovery context]; Joe Z. v. Superior Court (1970) 3 Cal.3d 797, 804 (Joe Z.) [discovery context]; Ballard v. Superior Court (1966) 64 Cal.2d 159, 167 (Ballard) [discovery context]; see also, e.g., F 2020In the process, we include additional relevant case citations to those set forth in Alhambra and Hoffstadt on Criminal Discovery: (1) Has the defendant carried his burden of showing a “ ‘plausible justification’ ” for acquiring documents from a third party (Kling v. Superior Court of Ventura County (2010) 50 Cal.4th 1068, 1075 (Kling); Hill v. Superior Court (1974) 10 Cal.3d 812 , 817–818 (Hill) [discovery context]; Joe Z. v. Superior Court (1970) 3 Cal.3d 797, 804 (Joe Z.) [discovery context]; Ballard v. Superior Court (1966) 64 Cal.2d 159, 167 (Ballard) [discovery context]; see also, e.g., F | 2 | 2020–2020 |
Pitchess v. Superior Court
red
2 sentences2020(Pitchess, supra, 11 Cal.3d at p. 535 ; see also Facebook (Hunter) II, supra, 46 Cal.App.5th at p. 118, rev. granted.) We conclude that the trial court below abused its discretion when ruling on the motion to quash by failing to apply the seven-factor Alhambra test. 2020(Pitchess, supra, 11 Cal.3d at p. 535 ; see also Facebook (Hunter) II, supra, 46 Cal.App.5th at p. 118, rev. granted.) We conclude that the trial court below abused its discretion when ruling on the motion to quash by failing to apply the seven-factor Alhambra test. | 2 | 2020–2020 |
Lemelle v. Superior Court
green
2 sentences2020In the process, we include additional relevant case citations to those set forth in Alhambra and Hoffstadt on Criminal Discovery: (1) Has the defendant carried his burden of showing a “ ‘plausible justification’ ” for acquiring documents from a third party (Kling v. Superior Court of Ventura County (2010) 50 Cal.4th 1068, 1075 (Kling); Hill v. Superior Court (1974) 10 Cal.3d 812 , 817–818 (Hill) [discovery context]; Joe Z. v. Superior Court (1970) 3 Cal.3d 797, 804 (Joe Z.) [discovery context]; Ballard v. Superior Court (1966) 64 Cal.2d 159, 167 (Ballard) [discovery context]; see also, e.g., F 2020In the process, we include additional relevant case citations to those set forth in Alhambra and Hoffstadt on Criminal Discovery: (1) Has the defendant carried his burden of showing a “ ‘plausible justification’ ” for acquiring documents from a third party (Kling v. Superior Court of Ventura County (2010) 50 Cal.4th 1068, 1075 (Kling); Hill v. Superior Court (1974) 10 Cal.3d 812 , 817–818 (Hill) [discovery context]; Joe Z. v. Superior Court (1970) 3 Cal.3d 797, 804 (Joe Z.) [discovery context]; Ballard v. Superior Court (1966) 64 Cal.2d 159, 167 (Ballard) [discovery context]; see also, e.g., F | 2 | 2020–2020 |
Warrick v. Superior Court
green
2 sentences2025(Warrick, supra, 35 Cal.4th at p. 1021 ; Riske v. Superior Court (2016) 6 Cal.App.5th 647, 656 .) Because defendant did not meet the threshold issue, we see no reason to address the Alhambra factors. 2025(Warrick, supra, 35 Cal.4th at p. 1021 ; Riske v. Superior Court (2016) 6 Cal.App.5th 647, 656 .) Because defendant did not meet the threshold issue, we see no reason to address the Alhambra factors. | 1 | 2025–2025 |
Riske v. Superior Court of Los Angeles County
green
2 sentences2025(Warrick, supra, 35 Cal.4th at p. 1021 ; Riske v. Superior Court (2016) 6 Cal.App.5th 647, 656 .) Because defendant did not meet the threshold issue, we see no reason to address the Alhambra factors. 2025(Warrick, supra, 35 Cal.4th at p. 1021 ; Riske v. Superior Court (2016) 6 Cal.App.5th 647, 656 .) Because defendant did not meet the threshold issue, we see no reason to address the Alhambra factors. | 1 | 2025–2025 |
People v. Gaines
green
1 sentence2024(Touchstone, supra, 10 Cal.5th at p. 359.) The court ultimately held that “in light of questions concerning whether the underlying subpoena is supported by good cause,” it would “direct the Court of Appeal to vacate the trial court’s denial of the motion to quash and instruct the trial court to reconsider that motion.” (Ibid.; cf. People v. Gaines (2009) 46 Cal.4th 172, 176 .) In Madrigal, supra, 93 Cal.App.5th 219 , the defendant was convicted of first degree murder and second degree robbery. | 1 | 2024–2024 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.