so serious that there is a reasonable probability that the suppressed evidence would have produced a different verdict." The prosecutor must disclose arrest photographs of the defendant when those photos do not match the victim's description. Some state systems have expansively defined Brady material to include many other items, including for example any documents which might reflect negatively on a witness's credibility. Police officers who have been dishonest are sometimes referred to as "Brady cops." Because of the Brady ruling, prosecutors are required to notify defendants and their attorneys whenever a law enforcement official involved in their case has a sustained record for knowingly lying in an official capacity. The growing use of Brady, both in the federal and state sectors, is one of the most important changes affecting police officers' employment. Procedures for compliance In order to ensure compliance with Brady, the United States Supreme Court repeatedly urged the "careful prosecutor" to favor disclosure over concealment. Conformity with Brady is a continuing obligation of prosecutors. Some prosecuting attorney offices have adopted and created specialized procedure and bureaus to meet their burden. Pitchess v. Superior Court is the source for a "Pitchess motion" in California. Such a motion can be made by a criminal defendant to discover complaints made against a police officer, and the investigation of those complaints, such that they are contained in the officer's personnel records. The motions can be made in a California Superior Court under California Evidence Code 1043-1046. Notwithstanding, because the broad nature of the discovery that the associated court rule and statute provide, getting actual records can be complicated. In California, there is a carefully prescribed procedure governing such request, and making disclosure without an order is a crime. The statutory scheme was developed, in part, because law enforcement departments had developed a practice of purging their files concerning misconduct claims made against their officers. See also Giglio v. United States Jencks Act Jencks v. United States Testilying References Further reading United States constitutional criminal procedure Legal doctrines and principles Criminal law legal terminology