People v. Holt CA2/6

Facts Appellant's house, vehicle and person were searched by the Ventura County Sheriff's Department pursuant to a warrant. Methamphetamine and stolen property recovered during the search formed the basis for offense to which appellant pled guilty. Probable cause for the search warrant was established, in part, by a confidential attachment to the search warrant affidavit. This document was sealed by the Superior Court. Appellant moved to unseal the confidential attachment and to traverse and quash the warrant. After conducting an in camera review, the trial court found the attachment had been properly sealed, that the affidavit was not subject to a motion to traverse and that it provided probable cause for issuing the warrant. Accordingly, the trial court denied appellant's motion. Discussion The sole issue raised on appeal is whether the trial court properly denied appellant's motion to unseal the confidential attachment and to traverse and quash the warrant. Where a defendant challenges a search warrant issued on the basis of confidential documents placed under seal, the trial court is required to conduct an in camera hearing. At that hearing, the trial court…