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Supreme Court of California case
Warrick v. Superior Court, (City of Los Angeles Police Department)
2005
Defendant seeking discovery of police officer personnel records is entitled to an in camera review upon filing a declaration containing a specific factual showing that officer misconduct could or might have occurred, and a showing that such misconduct is relevant.
In this case, defendant was charged with possession of cocaine for sale. He filed a declaration charging that said that the officers mistook him for the person who actually discarded the cocaine, and falsely accused him of having done so. This showing was sufficient to meet the plausibility standard and to entitle defendant to an in camera review to determine whether the officers' personnel records contained evidence of false arrests, planting of evidence, fabricating of police reports or probable cause, or commission of perjury.
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