State v. Chemuti

Summary

The Court held that N.C.G.S. § 132-1.4A provides the exclusive procedure for a criminal defendant in district court to obtain law-enforcement recordings covered by the statute: the defendant must seek an order from superior court in a county where part of the recording was made. The statute does not violate due process, compulsory process, or confrontation rights because it changes only the procedure for obtaining evidence, while requiring courts to release evidence constitutionally necessary to a complete defense. The Court also held that an order compelling disclosure of allegedly confidential information affects a substantial right and is immediately appealable.