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Name: People v. Superior Court (Meraz)
Case #: F054353
Court: CA Court of Appeal
District 5 DCA
Opinion Date: 05/21/2008

The trial court erred when it dismissed special circumstance allegation as sanction for discovery violations deemed improper under Brady v. Maryland. Meraz was the defendant in a capital murder trial. He sought to discover information concerning a vehicle stop and showup made after the homicide, and a police report concerning the initial interviews of witnesses to the shooting. The witness interview report could not be located and the questioning officer had since died. The prosecutor repeatedly represented that no reports concerning the traffic stop existed. During jury selection, the prosecutor learned that field interview cards and photographs related to the stop had been found. He disclosed the information to the defense, and the court questioned its exculpatory value. The trial court dismissed the special circumstance allegation as a sanction for the untimely disclosure. The appellate court granted the prosecutor’s request for relief, finding that the trial court’s power to impose partial dismissal as a sanction for a discovery violation is subject to the same limitation as its power to dismiss an entire charge as a sanction: It cannot do so unless dismissal is required by the federal constitution. Here, dismissal was not constitutionally required, so the trial court’s imposition of the sanction was improper.