The question resolved in this case is whether the reciprocal discovery provisions of the Criminal Discovery statute (Pen. Code, sec. 1054 et seq) apply to a provation revocation hearing, such that a probationer is obligated to provide discovery to the prosecution in such a proceeding. The appellate court here held that there is no such obligation. A probation revocation proceeding is not a criminal trial within the meaning of section 1054.3, and no other statutory authority provides for such discovery.
Case Summaries