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Name: People v. Jackson
Case #: F040888
Court: CA Court of Appeal
District 5 DCA
Opinion Date: 07/07/2003

This case was initially remanded so that the trial court could conduct an in camera review of police files of three uncharged similar burglaries to those of which defendant was accused. Appellant sought discovery in an attempt to show someone else committed the charged offenses. In a highly fact-specific case, the appellate court held it was not error to deny discovery in two of the cases. In the first, entry was factually dissimilar, since entry was forced and the crimes charged against appellant involved entry through unlocked or broken doors. In both the first and second case, no identification could be made of the perpetrator, and thus the files would not have lead to exculpatory evidence. As to the third case, the need for the confidentiality of an ongoing investigation and the privacy rights of the victim (who was also the victim of a sexual assault) outweighed any right to discovery of potentially exculpatory evidence.