Bridgeforth v. Superior Court
214 Cal. App. 4th 1074
| Cal. Ct. App. | 2013Background
- Bridgeforth charged with murder, attempted murder, shooting at an occupied vehicle, and felon in possession; case includes robbery-murder and gang-related special circumstances later struck at preliminary hearing.
- Parolee wearing GPS; location data show presence at Ralphs parking lot near time of shooting; Valenzuela testified from a white truck; Vinson’s car/trunk evidence from Shepard’s car later found to contain codeine bottles.
- Defense sought writ of mandate arguing failure to disclose Valenzuela’s truck photos violated Brady and due process; prosecutor disclosed video evidence before preliminary hearing.
- Prosecutor argued discovery statutes govern pretrial discovery and no due process right to prepreliminary disclosure; photos not favorable/helpful to defense.
- Court held: there is a due process right to prepreliminary disclosure of favorable and material evidence independent of discovery statutes; but the photos were not favorable or material, so no due process violation; denial of writ affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Right to prepreliminary disclosure of favorable material evidence | Bridgeforth asserts due process requires pre-hearing Brady materials | People rely on discovery statutes, not due process prehearing disclosure | Yes: due process requires prepreliminary disclosure of favorable/material evidence. |
| Whether Valenzuela truck photos were favorable/impeaching | Photos would undermine Valenzuela’s credibility | Photos were not exculpatory or impeachment evidence; potentially inculpatory | No: photos were not favorable or material for probable cause. |
| Effect of Prop. 115 on due process discovery rights | Prop. 115 narrows/preludes nonstatutory discovery rights | Prop. 115 preserves dismissal rights not limited by discovery statutes | Prop. 115 does not bar due process claims; rights remain independent. |
Key Cases Cited
- Izazaga v. Superior Court, 54 Cal.3d 356 (Cal. 1991) (due process independent of statutory discovery rights)
- Stanton v. Superior Court, 193 Cal.App.3d 265 (Cal. App. 1987) (preliminary hearing rights and discovery obligations)
- Merrill v. Superior Court, 27 Cal.App.4th 1586 (Cal. App. 1994) (prepreliminary disclosure standards; materiality framework)
- People v. Gutierrez, 214 Cal.App.4th 343 (Cal. App. 2013) (Prop. 115 and Stanton/Merrill lineage on prehearing Brady material)
- Ruiz v. United States, 536 U.S. 622 (U.S. 2002) (plea-bargaining impeachment info disclosure considerations)