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Constitutional

4th District Court of Appeal, Division One
Uncategorized

Voice of San Diego v. San Diego Unified School District — Court Holds CPRA’s “Promptly Available” Standard Is Flexible, Not a Fixed Deadline

The Fourth District holds that the CPRA’s “promptly available” production standard is a flexible, context-dependent requirement — not a fixed deadline — and sets out a multi-factor test for courts to evaluate agency compliance.

4th District Court of Appeal, Division One
Uncategorized

People v. Zapata — Confession to Undercover ‘Perkins’ Operatives Inadmissible When Suspect Had Invoked Right to Counsel

Fourth District reverses a second-degree-murder conviction, holding that statements obtained from a defendant during an undercover Perkins operation were inadmissible under Miranda because the suspect had invoked his right to counsel and a known law-enforcement officer continued to ‘stimulate&

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