In People v. Sassounian (1986) 182 Cal. App. 3d 361, the defendant argued the prosecution had engaged in misconduct by willfully suppressing jail records that would have shown his alleged jailhouse confession was fabricated. Although the defendant asserted the trial court should have granted a mistrial or given the jury a directive instruction regarding the contents of the record, the court found the trial court acted within its discretion by instructing the jury that "if it found that the sheriff had willfully 'lost' or destroyed the jail record it could presume that such record was unfavorable to the People's case." (Id. at p. 395.) In finding this instruction appropriate, the court explained that the evidence in question must be "substantial material evidence," that is, evidence possessing an exculpatory value. (Id. at pp. 395-396 & fn. 34.)