State v. Andres C.

Summary

The court affirmed the defendant’s convictions, holding that the complainant’s therapy journals were not discoverable witness statements because she did not sign, adopt, or approve them as a formal account for which she could be held accountable. The court also held that the Constitution did not require the trial prosecutors personally to review the journals for favorable evidence; a qualified staff member could assist, subject to the prosecutor’s ultimate responsibility for compliance with Brady. The court declined to adopt a prophylactic rule requiring personal review by the trial prosecutor.