People v. Young CA5, F079921

Defendant Toraino Young, an inmate at Kern Valley State Prison, was charged with assault with a deadly weapon by an inmate and alleged prior strikes; after a bench trial he was convicted and sentenced to 25 years-to-life.
On October 20, 2015, Young struck inmate Kio Simmons repeatedly on the right side of the head/face; three correctional officers (Robles, Gurrola, Vera) observed the incident from yards away; a sharpened, inmate-made plastic weapon was found near the scene.
Medical testimony tied Simmons’ neck and chin puncture wounds to the weapon and described injuries on Young’s right hand (scabbing, swelling) consistent with fighting or using the weapon.
Young’s counsel filed two Pitchess motions seeking officer personnel/Brady material; both were denied. Counsel declined to seek a continuance to pursue additional Pitchess discovery before trial because Young did not want delay.
On appeal Young argued trial counsel was ineffective for failing to file a third Pitchess motion seeking personnel/Brady records for several officers; the trial court and appellate court found counsel’s tactical choice reasonable and that Young suffered no prejudice.
The court emphasized (1) insufficient factual specificity to establish good cause for Pitchess discovery for several officers and (2) that any disclosed personnel evidence would not likely have produced a different verdict given eyewitness and medical evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel was ineffective for not filing a third Pitchess motion for officer personnel/Brady files	People: counsel’s decision was a reasonable tactical choice and no prejudice shown	Young: counsel’s failure deprived him of evidence that could impeach officers and change the result	Court: affirmed — counsel reasonably declined (client refused continuance); defendant failed to show good cause or prejudice

Pitchess v. Superior Court, 11 Cal.3d 531 (establishes procedure for compelled discovery of police personnel files)
Rezek v. Superior Court, 206 Cal.App.4th 633 (explains Pitchess good-cause standard and required factual specificity)
Strickland v. Washington, 466 U.S. 668 (establishes ineffective-assistance two-part test)
People v. Superior Court (Johnson), 61 Cal.4th 696 (discusses Pitchess motion requirements)
Brady v. Maryland, 373 U.S. 83 (prosecution's duty to disclose exculpatory/impeachment material)
People v. Sanderson, 181 Cal.App.4th 1334 (holding that mere dispute of facts in an officer’s report is insufficient to show Pitchess good cause)