Lee Max Barnett, Petitioner v. the Superior Court of Butte County, Respondent; the People, Real Party in Interest

Summary

The court held that postconviction discovery under Penal Code section 1054.9 is limited: a capital defendant seeking materials beyond reconstruction of the trial file must show a reasonable basis to believe specific materials exist, but need not establish their materiality before obtaining them. The statute does not require the prosecution to obtain materials held by out-of-state law enforcement agencies that merely provided limited assistance and were not part of the California prosecution team. The court reversed the Court of Appeal's judgment and remanded for further proceedings consistent with those principles; Justice Werdegar, dissenting, would have allowed discovery of materials generated by out-of-state agencies acting at the prosecutor's request and rejected the majority's threshold-existence requirement.