State of New Jersey, Plaintiff-Respondent v. Paul Doliner, M.D., Anthony Todaro, ph.D., Marlene Todaro and Central…

Summary

The New Jersey Supreme Court adopted a "strong showing of particularized need" test for governmental disclosure of grand jury materials, balancing that need against the public interest in grand jury secrecy. It affirmed the trial court's order releasing the defendants' billing and medical records to the State, but remanded for further determination of the remaining materials sought. The decision harmonizes New Jersey standards with the federal rule articulated in United States v. Sells.