People v. White

Opinion

PERREN, J.

The procedures attendant to a criminal defendant’s right to discover relevant evidence in confidential peace officer personnel files— through the filing of a so-called “Pitchess”1 motion—are established by both statute and decisional law.2 The defining hallmark of the process is an in camera hearing in which the trial court reviews the files at issue outside the presence of the defendant and his or her counsel. The completeness of the records is established through questioning of the custodian of records who produced them. In order to protect the defendant’s right to a fair…