State Supreme Court rules prisoners have common law right to inspect evidence held by the court

In a matter of first impression, the state Supreme Court determined there is a presumption that post-conviction evidence under the court's control is open for inspection.

Petitioner William Tupua Satele was sentenced to death in 2013 for the first degree murders of Renesha Ann Fuller and Edward Robinson. After conviction, petitioner's habeas counsel sought to reexamine the ballistic evidence, which were trial exhibits and lodged with the court.

Citing a lack of good cause, the trial judge denied Satele access to the physical evidence under any circumstances.

The 2nd District Court of Appeal summarily denied Satele's petition for writ of mandate, and the state Supreme Court denied review.

The state Supreme Court, however, took the unusual move of taking up, sua sponte and under its original jurisdiction, the issue of what the correct standard is for the court to release post-conviction evidence.

Writing for the unanimous majority, Justice Carol Corrigan relied on the general common law right to inspect public records, including judicial records, to find that there is a presumption that post-conviction evidence under the court's control is open for inspection.

"Court documents, including exhibits, ... may be released subject to such conditions the court deems necessary to safeguard their integrity," Corrigan wrote. Satele v. Superior Court of Los Angeles, 2019 DJDAR 6669 (Cal. July 18, 2019).

As a result, the state Supreme Court ruled the trial court erred in denying the petitioner access to the evidence for lack of good cause and remanded the case back to Los Angeles County Superior Court to give the ballistic evidence to the petitioner.