Background

• Petitioner William Tupua Satele was sentenced to death for two first-degree murders; a semiautomatic gun seized from his car was identified at trial as the murder weapon by ballistics comparison.
• After direct appeal affirmed, habeas counsel sought ballistics materials and trial exhibits (bullets, casings, the weapon) for independent testing; the exhibits were held by the court clerk.
• Counsel initially invoked Penal Code § 1054.9 but clarified at hearing that the requested evidence was court-held, not in the prosecutor’s possession.
• The superior court denied access, finding Satele had not shown the “good cause” required by § 1054.9(d) — that access was reasonably necessary to obtain relief.
• The Court of Appeal summarily denied relief; the California Supreme Court granted review to decide whether § 1054.9’s good-cause requirement applies to evidence held by the court clerk.
• The Supreme Court concluded § 1054.9 governs discovery of materials in possession of the prosecution or law enforcement, not court-held exhibits; the trial court therefore erred in applying § 1054.9(d) and must reconsider release under the court’s inherent authority.

Issues

Key Cases Cited

• People v. Superior Court (Morales), 2 Cal.5th 523 (clarifies § 1054.9 discovery applies to materials in prosecution or law enforcement possession)
• In re Steele, 32 Cal.4th 682 (discusses limits of defendant’s discovery from prosecutors and investigating agencies)
• People v. Gonzalez, 51 Cal.3d 1179 (background on postconviction discovery limitations)
• Nixon v. Warner Communications, Inc., 435 U.S. 589 (establishes common-law right of public access to judicial records)
• Sander v. State Bar of California, 58 Cal.4th 300 (recognizes public access presumption for judicial records)