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Pennsylvania v. Ritchie | 480 U.S. 39, 107 S.Ct. 989, 94 L.Ed.2d 40 (1987)
Are criminal defendants entitled to pretrial discovery under the Sixth Amendment’s Confrontation Clause? We explore that question in Pennsylvania versus Ritchie.
George Ritchie’s minor daughter accused him of sexual abuse. The matter was referred to Pennsylvania’s Children and Youth Services, also known as CYS, which investigated her claim. A state statute provides that, subject to certain exceptions, CYS records are confidential.
The commonwealth charged Ritchie with several sexual offenses. Ritchie subpoenaed CYS and sought certain records relating to allegations of child abuse against him. CYS asserted that the records were privileged and refused to produce them. Ritchie filed a motion for sanctions and argued that he was entitled to review the files because they might contain exculpatory evidence. The trial court denied Ritchie’s motion. Ritchie’s counsel thoroughly cross examined his daughter at trial. The jury convicted.
Ritchie appealed to the Pennsylvania Superior Court, which found that the trial court’s refusal to require production of the CYS files violated the Sixth Amendment’s Confrontation Clause. It remanded the matter with instructions to the trial court to review the files and to produce any verbatim statements of Ritchie’s daughter to the defense.
The commonwealth appealed to the Pennsylvania Supreme Court. That court found that the trial court had violated both the Confrontation Clause and the Compulsory Process Clause of the United States Constitution by denying Ritchie access to the CYS files. The Pennsylvania Supreme Court ruled that Ritchie’s counsel could review the files to identify useful information. The United States Supreme Court granted cert.
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