Complaint No. 1778437082 - 114231557

Mr. Hochman has continued LADA’s unconstitutional pattern and practice of failing to make Brady/Giglio disclosures concerning the Los Angeles County juvenile-hall conspiracy by permitting prosecutions, juvenile adjudications, probation-violation proceedings, and related custodial matters to proceed without affirmative disclosure of known or suspected Los Angeles County Probation Department staff misconduct, coordinated youth-on-youth violence, falsified reporting, concealment, retaliation, excessive force, child endangerment, abuse, battery, or conspiracy evidence.

This failure is especially material where Los Angeles County Probation Department personnel serve as complaining witnesses, incident-report authors, use-of-force witnesses, custodial witnesses, declarants, affiants, transportation officers, juvenile-hall housing staff, investigators, or recurrent prosecution witnesses. The Attorney General has publicly alleged that 30 detention services officers at Los Padrinos Juvenile Hall were indicted for child endangerment and abuse, conspiracy, and battery arising from 69 alleged fights involving 143 youth victims between July 1, 2023, and December 31, 2023. The Attorney General further identified the matter as part of broader unsafe and unlawful juvenile-hall conditions, including staff-facilitated youth-on-youth violence, retaliation concerns, contraband failures, unmet medical needs, and persistent County noncompliance with court-enforced remedial obligations. 

Because the existence of this charged juvenile-hall conspiracy is a known variable affecting witness credibility, bias, motive, coercion, falsification, retaliation, use of force, child endangerment, concealment, institutional self-protection, and the reliability of official custodial reports, LADA cannot discharge its Brady/Giglio obligations by relying on ordinary discovery representations, probation-generated incident reports, or the Probation Department’s internal characterization of what is or is not impeachment material. LADA’s own policy recognizes that Brady obligations apply during juvenile adjudications, that potentially exculpatory or impeaching evidence must be disclosed as soon as it becomes known, and that recurrent prosecution-witness impeachment information is tracked through its Discovery Compliance System. 

The known persistence of this undisclosed impeachment category renders LADA’s Brady/Giglio disclosures presumptively incomplete in juvenile-hall-implicated cases unless independently verified. This includes any case in which Los Angeles County Probation Department personnel supplied reports, testimony, chain-of-custody evidence, use-of-force accounts, disciplinary narratives, statements about youth behavior, statements concerning assaults, statements concerning contraband, or statements used to support detention, adjudication, disposition, transfer, probation violation, or adult-court consequences.

Accordingly, no disclosure from LADA in such cases should be trusted as complete, accurate, or constitutionally sufficient without third-party verification, including independent review of Attorney General investigative materials, grand-jury materials subject to lawful access, Probation Department personnel and misconduct records, use-of-force records, incident video, grievance records, medical records, internal affairs materials, staff assignment logs, prior civil-rights litigation, County Counsel materials where discoverable, juvenile-court oversight records, BSCC findings, Probation Oversight Commission records, and any records held by state or County monitoring entities. Absent such verification, LADA’s discovery responses should be treated as structurally unreliable and insufficient to satisfy due process in any case affected by the Los Angeles juvenile-hall conspiracy.