People v. Grimes CA3

BACKGROUND

As relevant here, two officers responded to a domestic disturbance in July 2022. The victim, who had a large lump on her forehead, was distraught and explained to the responding officers that Grimes had caused the injury. The People charged Grimes with inflicting corporal injury on a cohabitant (Pen. Code, § 273.5, subd. (a)) and assault on a peace officer (Pen. Code, § 245, subd. (c)). Grimes moved for discovery of any materials, including personnel files, showing that the responding officers had “engaged in acts of misconduct and/or dishonesty.” After conducting an in camera examination of the Pitchess materials, the trial court denied the motion. A jury ultimately found Grimes guilty of inflicting corporal injury and not guilty of assault on a peace officer. The court sentenced Grimes to the middle term of three years. Grimes filed a notice of appeal with this court in March 2023. His opening brief was filed in December 2023, and this case was fully briefed on April 22, 2024.

DISCUSSION

Grimes asks this court to conduct an independent review of the sealed records of the trial court’s hearing on his Pitchess motion. (People v. Mooc (2001) 26 Cal.4th 1216,…