People v. Sauls

Summary

The court held that the trial court violated defendant's due process rights by quashing a subpoena for confidential child-welfare records without first conducting an in camera review. Defendant made a sufficient good-faith showing that the records might contain impeachment or other material evidence, so the case was remanded for review and a determination whether disclosure would warrant a new trial. The court also held that the trial evidence was sufficient to support the conviction beyond a reasonable doubt.