Roland

Taneka Roland, the defendant in a criminal prosecution, seeks writ relief to compel the trial court to vacate its order directing her attorney to provide the prosecution with reports of relevant unrecorded oral statements provided to the defense by persons, other than Roland, whom her attorney intends to call as witnesses at trial. We issued an alternative writ and stayed further proceedings in the trial court pending our resolution of the discovery dispute.

This proceeding requires us to interpret section 1054.3 of the Penal Code, which governs the discovery obligations of parties to a criminal prosecution. (Further section references are to the Penal Code unless otherwise specified.) In Roland’s view, that section compels the defense to disclose to the prosecution only relevant videotaped, tape-recorded, or written statements of witnesses whom defendant intends to call at trial; it does not require the defense to provide the prosecution with reports of relevant unrecorded oral statements made by defense witnesses. We disagree.

As we will explain, based upon the plain meaning of the words and the grammar used in section 1054.3, considered together with the purpose of…