The accused applied for further disclosure to challenge the validity of search warrants executed at a storefront cannabis dispensary and his residence.
The requested disclosure included police notes, communications records, occurrence reports involving an alleged confidential informant, and portions of a police manual regarding confidential informer status.
The applicant argued the materials were necessary to challenge the credibility of the affiant officer and to support cross‑examination regarding the issuance of the warrants.
The court held that even if some affidavit information were inaccurate or incomplete, the remaining uncontested information independently satisfied the statutory preconditions for issuing the warrants.
As a result, the credibility of the affiant was not material and the requested disclosure was neither relevant nor necessary to permit full answer and defence.
