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P. v. Biddle CA1/4
A jury convicted appellant Marcus Charles Biddle of possession for sale of methamphetamine in violation of Health and Safety Code section 11378, for which he was placed on three years formal probation, with 234 days to be served in county jail. Biddle appeals, challenging the admission of a confession he made to the police on grounds it was involuntary. He also requests that this court conduct an independent review of the trial court’s denial of his Pitchess motion following an in camera hearing. (See Pitchess v. Superior Court (1974) 11 Cal.3d 531 (Pitchess).) We see no error in the admission of his confession but we find the record inadequate to conduct meaningful review of the court’s denial of the Pitchess motion and will conditionally reverse on that basis.

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