Confidential information

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Evidence Code sections 1040 to 1042

Protects confidential information as well informants.

In re David W. (1976) 62 Cal.App.3d 840, allowed location of VIN information to be kept confidential.

People v. Otte (1989) 214 Cal.App.3d 1522, clarified what "furnished in confidence" means.

Confidential informants

People v. Johnson (1970) 13 Cal.App.3d 742 - DA is holder of privilege not to disclose the informatn's identity. Communications are not privileged except if communications would assist in identifying the informant.

1042 in camera hearing

People v. Alderrou (1987) 191 Cal.App.3d 1074 - defense failed to establish need for in camera holding becaues it would not exonerate the defendant

People v. Fried (1989) 214 Cal.App.3d 1309

PC701.5 - minor informants. <12-yo prohibited. 12<x<18 only allowed with court order.

Chapter II, section 1.3 of CDAA Search Warrants book.

Roviaro v. United States (1957) 353 U.S. 53 - disclosure required

Honore v. Superior Court of Alameda County (1969) 70 Cal.2d 162 - disclosure required

People v. Garcia (1967) 67 Cal.2d 830 - disclosure required

In re Tracy J. (1979) 94 Cal.App.3d 472

People v. McCoy (1970) 13 Cal.App.3d 6 - disclosure not required.

People v. Hardeman (1982) 137 Cal.App.3d 823 - disclosure not required when CI is not present when search warrant is served

People v. Oppel (1990) 222 Cal.App.3d 1146 - Affidavit of attorney based on informatn and belief is not evidence.

Eleazer v. Superior Court (1970) 1 Cal.3d 847 - LE's duty towards informant.

People v. Holiday (1973) 8 Cal.3d 771

People v. Callen (1987) 194 Cal.App.3d 558

Appellate review

People v. Barkins (1978) 81 Cal.App.3d 30

Types of informants

Citizen informants

People v. Ramey (1976) 16 Cal.3d 263

People v. Hill (1974) 12 Cal.3d 731, 761

People v. Kurland (1980) 28 Cal.3d 376

People v. Lombera (1989) 210 Cal.App.3d 29 - citizen informant need not be disclosed.

People v. Schulle (1975) 51 Cal.App.3d 809 - citizen informant with record is still citizen informant. Motivated by good citizenship.

Untested informant

Confidential reliable informant

Police officers are reliable - Hill

Victims or witnesses of crimes are reliable - Ramey

Humphrey v. Appellate Division (2002) 29 Cal.4th 569

Skelton v. Superior Court (1969) 1 Cal.3d 144 - procedure for making a CI reliable

People v. Mayer (1986) 188 Cal.App.3d 1101

People v. Murphy (1974) 42 Cal.App.3d 81

People v. French (2011) 201 Cal.App.4th 1307 - informant found not reliable, but good faith exception

Criminal history

People v. Kurland (1980) 28 Cal.3d 376 People v. Webb (1993) 6 Cval.4th 494

People v. Aho (1985) 166 Cal.App.3d 984

People v. Cobb (1983) 146 Cal.App.3d 290 - omissions from an affidavit of negative background information about an informant as well as informant's motivation for assisting the police are material facts and failing to include them in a search warrant affidavit will lead to search warrant being quashed.

Defense counsel

Boulas v. Superior Court (1986) 188 Cal.App.3d 422

People v. Hayes (1988) 200 Cal.App.3d 400


Surveillance locations

Hines v. Superior Court (1988) 203 Cal.App.3d 1231

People v. Montgomery (1988) 205 Cal.App.3d 1011

People v. Walker (1991) 230 Cal.App.3d 230

In re Sergio M. (1993) 13 Cal.App.4th 809

People v. Haider (1995) 34 Cal.App.4th 661

People v. Garza (1995) 32 Cal.App.4th 148

People v. Lewis (2009) 172 Cal.App.4th 1426


Jail snitches

PC1127a

PC1111.5

PC1191.25

PC4001.1

People v. Huggins (2015) 235 Cal.App.4th 715

People v. Williams (1997) 16 Cal.4th 153