Supreme Court of the United States
Pennsylvania v. Ritchie
February 24, 1987480 U.S. 39
Summary
The Court held that it had jurisdiction despite further proceedings remaining in state court and that due process entitled Ritchie to judicial review of confidential child-abuse records for material favorable evidence, but not to inspection of the entire file by defense counsel. It affirmed the remand requirement, reversed the requirement of defense access, and remanded for in camera review. Powell's four-Justice plurality, joined by Rehnquist, White, and O'Connor, additionally concluded that withholding the records did not violate the Confrontation Clause because cross-examination at trial was unrestricted. Blackmun joined the Court's other holdings and judgment but wrote separately that pretrial withholding could implicate confrontation rights; he considered judicial review adequate to address those concerns. Brennan, joined by Marshall, dissented, arguing that denial of access to the victim's prior statements violated the Confrontation Clause, and also joined Stevens's jurisdictional dissent. Stevens, joined by Brennan, Marshall, and Scalia, would dismiss the writ because the state judgment was not final.
Holding
- Finality of the state judgment for Supreme Court review.. The Court had jurisdiction despite anticipated proceedings on remand because the federal disclosure issue had been finally decided and later review might be unavailable regardless of the eventual outcome.
- The defendant's entitlement to material favorable evidence in confidential child-abuse records.. Ritchie was entitled to have the trial court review the CYS file for information that probably would have changed the trial's outcome. Material favorable information required a new trial; absent such information, or if nondisclosure was harmless beyond a reasonable doubt, the conviction could be reinstated.
- Whether defense counsel must be permitted to inspect the entire confidential file.. Defense counsel had no constitutional right to inspect the entire CYS file; in camera review by the trial court adequately protected the defendant's interests.
- Whether withholding the CYS file violated the Confrontation Clause.. The four-Justice plurality concluded that withholding the file did not violate the Confrontation Clause because defense counsel was permitted to cross-examine the trial witnesses fully.
Docket 85-1347
Cited authorities
- Pennsylvania Rule of Appellate Procedure 311(a)(5)
- CA10
- 28 U.S.C. § 1257
- 42 Pa. Cons. Stat. § 5945.1
- 28 U.S.C. § 1257
- 73 Mich. L. Rev. 71
- 23 Vill. L. Rev. 458
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