In Re the People of the State of Colorado, Plaintiff v. Brittney Breann Angel, Defendant

Summary

The court held that prosecutorial opinion work product protected by Crim. P. 16(I)(e)(1) includes materials prepared in anticipation of any criminal prosecution, not only the prosecution pending before the trial court. The protection covers legal strategies, opinions, impressions, and conclusions, but not purely factual work product, and it does not eliminate disclosure obligations for exculpatory material. The court made the rule absolute, reversed the discovery order, and remanded for an ex parte, in camera determination of whether the disputed materials are protected opinion work product.