Uybungco
Uybungco v. Superior Court of San Diego County
Opinion
Opinion
Irion, J.
— Jose Uybungco seeks reversal of a trial court ruling denying his motion for discovery from the personnel files of four police officers involved in his arrest on misdemeanor charges. Uybungco contends that the trial court erred because his motion satisfied the low threshold required to obtain limited discovery from police personnel files under Pitchess v. Superior Court (1974) 11 Cal.3d 531 [ 113 Cal.Rptr. 897 , 522 P.2d 305 ] (Pitchess). As discussed below, we agree with Uybungco’s contention and grant the petition.
FACTS
The charges against Uybungco arise out of an event that is summarized in the reports of four separate police officers. Because Uybungco requested discovery from the personnel files of each of the four officers, alleging that the reports were falsified, each report is summarized independently below.
A. Police Officer Report: Officer Hall
On April 6, 2007, San Diego Police Department Officers Hall and Curran observed a fight involving patrons of the Red Circle Café (Red Circle) in downtown San Diego. The officers identified themselves and instructed the bar patrons to stop fighting. One of the patrons, Robert Anguiano, did not comply. While Officer…