J.E. v. Superior Court, 168 Cal. Rptr. 3d 67

J.E., a minor, was charged in juvenile court with petty theft and lewd conduct; defense sought juvenile dependency records of prosecution witness E.W. for Brady (exculpatory/impeachment) material.
Defense filed a Welfare & Institutions Code §827 petition asking the juvenile court to conduct an in camera review of E.W.’s juvenile file.
The juvenile court refused, ruling Brady review is the prosecutor’s duty (Pen. Code §1054.1/Brady) and declined to inspect the file under §827.
Defense separately requested the prosecutor to disclose child welfare/police reports; the prosecutor reviewed the records and reported no Brady material.
Defense sought a writ directing the juvenile court to perform the §827 in camera review; the People (DA) conceded the court erred in refusing to review.
The appellate court held that where a §827 petition shows a reasonable basis to believe the juvenile file contains Brady material, the juvenile court must conduct an in camera review and balance confidentiality against disclosure.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a juvenile court must conduct an in camera review under §827 when defense shows a reasonable basis that juvenile records contain Brady material	J.E.: §827 petition may require the court to inspect confidential juvenile files in camera to identify Brady exculpatory/impeachment material; court is the appropriate gatekeeper	Juvenile court/People (initially): Brady duties are for the prosecutor to perform; court should not conduct pretrial review of prosecution's discovery obligations	Held: Where petitioner shows a reasonable basis that juvenile file contains Brady material, juvenile court must conduct an in camera review under §827 and balance confidentiality against disclosure
Whether Brady obligations can be satisfied by court in camera review of confidential juvenile files	J.E.: In camera court review is an appropriate means to protect confidentiality while fulfilling Brady	People (initially): Prosecutor should search and disclose; court review unnecessary	Held: Court in camera review is an acceptable and often necessary mechanism to satisfy Brady while preserving confidentiality; the court should perform the review upon a proper §827 showing

Brady v. Maryland, 373 U.S. 83 (1963) (constitutional duty to disclose exculpatory/impeachment evidence)
Pennsylvania v. Ritchie, 480 U.S. 39 (1987) (trial court in camera review of child-protection records can protect confidentiality while fulfilling Brady; requires threshold showing)
People v. Salazar, 35 Cal.4th 1031 (2005) (Brady material must be favorable and material; prosecution duty described)
People v. Webb, 6 Cal.4th 494 (1993) (impeachment evidence included within Brady obligations; courts must examine privileged files in camera when confidentiality asserted)
Joe Z. v. Superior Court, 3 Cal.3d 797 (1970) (Brady duty applies in juvenile delinquency proceedings)