Serrano v. Superior Court
Annotate this CaseThe Court of Appeal granted a petition for writ of mandate and directed the superior court to vacate its order denying petitioner's motion for in camera review and pretrial disclosure of potential impeachment material the district attorney informed him was contained in the personnel file of the arresting deputy, who was expected to testify at petitioner's trial. Petitioner was charged with the sale and transportation of a controlled substance. The court held that, under People v. Superior Court, 61 Cal.4th 696, counsel's declaration was sufficient to trigger in camera review of the deputy's personnel file, and it was error for the superior court to deny petitioner's motion on the ground that he failed to allege specific officer misconduct; Warrick v. Superior Court, 35 Cal.4th 1011, did not apply where Brady material was known to exist in an officer's personnel file; and the Supreme Court has held that no particularized showing was required to trigger in camera review for Brady material in other confidential files.
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