SAN FRANCISCO — A California state appellate court on Monday handed down a ruling that could make it increasingly harder for white-collar criminal defendants to get their hands on evidence potentially helpful to their case.

The First District Court of Appeal ruled that a law firm cooperating with San Mateo County investigators in an embezzlement investigation involving a former software company CEO wasn’t a member of the prosecution team. That means that the government doesn’t have a constitutional duty to look for potentially defense-friendly material in the files of Valla & Associates Inc., the law firm representing Foster City-based IAR Systems Software Inc. in a companion civil case.

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