State of Connecticut v. William Fay

Summary

The court held that a homicide defendant may be constitutionally entitled to in camera review of a deceased victim's privileged psychiatric records when the defendant makes a compelling showing that the records are material to a self-defense claim and unavailable from other sources. The defendant's claim was unpreserved, however, and the record did not establish the required connection between the victim's psychiatric condition or medications and aggressive behavior. The court therefore affirmed the manslaughter conviction.