Randolph Clifton Kling, Petitioner v. the Superior Court of Ventura County, Respondent; the People, Real Party In…

Summary

The court held that the People are entitled to notice of, and may participate and argue at, a hearing concerning defense subpoenas for third-party records when the trial court permits it. The People may also generally learn the subpoenaed party's identity and the nature of the requested records because due process may require a meaningful opportunity to challenge the discovery, subject to protections for privilege, work product, and defense strategy. The judgment was reversed and the matter remanded for application of these standards to the sealed hearing transcripts.