What is the test for in camera review of mental health treatment records in a civil case?

California, United States of America


The following excerpt is from People v. Ransom, E072090 (Cal. App. 2020):

When a defendant seeks confidential information, and makes a showing sufficient to justify in camera inspection, the trial court must examine those documents and make a record of what it has examined. (People v. Mooc (2001) 26 Cal.4th 1216, 1229.) After conducting in camera review, the trial court has discretion regarding which documents, if any, it will disclose to the party seeking discovery. (Ibid.) Defendant requests, and the People do not object, that we review the sealed record of the trial court's in camera review of the victim's mental health treatment records.

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