Matthew J. Zoll, Petitioner v. the People of the State of Colorado, Respondent.

Summary

The court held that when an appellate court determines that a trial court improperly withheld documents discovered through in camera review, it must remand for disclosure and allow the defendant to show a reasonable probability of prejudice. The court also held that any error in replaying the recording during deliberations outside Zoll's presence was harmless beyond a reasonable doubt, without deciding whether the replay constituted a critical stage. The judgment was reversed in part, affirmed in part on different grounds, and remanded.