Hale v. Superior Court CA4/1, D078515

Hale was convicted in the late 1990s of multiple violent felonies and sentenced to an indeterminate life term plus additional time.
In June 2020 Hale (pro se) requested postconviction discovery under Penal Code §1054.9 seeking police reports, witness statements, witness-relocation records, and copies of discovery provided to trial counsel; trial counsel was deceased and Hale alleges he could not obtain files from counsel.
The trial court denied Hale’s habeas petition/motion for §1054.9 discovery as overbroad and for failing to show how requested materials were essential to habeas claims, relying on Steele and Satele.
This Court treated Hale’s filing as a petition for writ of mandate, issued an alternative writ, and directed the trial court to reconsider; the trial court again denied discovery as overbroad.
The Court of Appeal held the trial court applied the wrong legal standard and abused its discretion by issuing a blanket denial; it granted relief in part and remanded for individual consideration of each request under §1054.9.

Issue	Plaintiff's Argument (Hale)	Defendant's Argument (People/DA)	Held
Whether §1054.9 allows pre-filing discovery when preparing a habeas petition	§1054.9 permits discovery to prepare a petition	Habeas is for vindicating claims; discovery should not be allowed before a petition	Allowed: §1054.9 authorizes discovery pre-filing to assist in preparing a petition (Steele)
Whether petitioner must show how requested materials support specific habeas grounds	No general showing required for non-physical materials	Must explain how materials will support habeas relief	Rejected: only physical evidence requires a separate good-cause showing; otherwise no need to link requests to specific grounds
Whether Hale’s requests are too vague/overbroad (Barnett concern)	Many requests are file-reconstruction requests and are reasonably specific	Requests are fishing expeditions and seek unlimited discovery	Trial court erred to deny blanketly; must evaluate each request and apply Barnett’s reasonable-basis requirement for non-file-reconstruction items
Proper procedure/remedy to challenge denial	Treat petition as §1054.9 motion and seek writ if court abuses discretion	Procedural defects argued but not decisive	Writ granted in part: appellate court directed trial court to treat petition as motion (if not already) and reconsider each request individually under §1054.9

In re Steele, 32 Cal.4th 682 (clarifies scope of §1054.9 and permits pre-filing discovery to prepare a habeas petition)
Satele v. Superior Court, 7 Cal.5th 852 (reiterates statutory entitlement to discovery upon satisfying §1054.9 requirements)
Barnett v. Superior Court, 50 Cal.4th 890 (limits open-ended fishing expeditions; requires reasonable basis to believe non-file-reconstruction materials exist)
People v. Gonzalez, 51 Cal.3d 1179 (historic rule that habeas was not for investigation; context for §1054.9 statutory change)
People v. Superior Court (Morales), 2 Cal.5th 523 (explains §1054.9 provides discovery as a matter of right when statutory predicates met)
Davis v. Superior Court, 1 Cal.App.5th 881 (rejects blanket denial; supports individualized review of §1054.9 requests)