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Cal. Decisions Tomorrow

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Tomorrow (Thursday), the California Supreme Court will announce decisions in two criminal cases.

People v. Gaines, S157008: "The court limited review to the following issue: Is outright reversal or a remand for a showing of prejudice the appropriate remedy for a trial court's erroneous denial of a Pitchess motion (Pitchess v. Superior Court (1974) 11 Cal.3d 531)?"

Pitchess motions seek discovery of police officers' personnel records.

People v. Lawrence, S160736: "This case presents the following issues: (1) Did the trial court abuse its discretion by denying a self-represented defendant's requests for appointment of counsel prior to opening argument? (2) Is the erroneous denial of a motion for reappointment of counsel made after the commencement of trial automatically reversible as structural error?"

Update: The opinions are out in Gaines and Lawrence. No surprises. The list of errors reversible per se is short and not growing.

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