R.S./s.E. v. Hon. thompson/teddy Vanders

Summary

The court held that a criminal defendant's due process right to present a complete defense can require in-camera review of a victim's privileged mental health records when the defendant shows a reasonable possibility that the records contain evidence material to the defense or necessary for cross-examination. Applying that standard, the court concluded that the defendant identified specific records that could corroborate his justification defense and affirmed the trial court's order for in-camera review while vacating the court of appeals' contrary decision.