GALINDO v. SUPERIOR COURT OF LOS ANGELES COUNTY Part-II
Charged by felony complaint with threatening and resisting an arresting officer in the performance of his duties (Pen. Code, §§ 422, 69), petitioner Moises Galindo brought a Pitchess motion (see Pitchess v. Superior Court (1974) 11 Cal.3d 531; Evid. Code, §§ 1043-1045) for disclosure of prior citizen complaints made against the arresting officer and four other officers involved in the incident.
Pitchess motions are so named after this court's 1974 decision in Pitchess v. Superior Court, supra, 11 Cal.3d 531, which afforded criminal defendants a judicially created right to discovery of prior citizen complaints alleging misconduct by California peace officers. In 1978, the Legislature codified the right and set forth which officer records are subject to Pitchess discovery. (Pen.
Code, §§ 832.7, 832.8; Evid. Code, §§ 1043-1045.) As relevant here, these statutes permit a criminal defendant to â€
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