When will the court order an in camera review of an in-camera review of a child abuse file?

California, United States of America


The following excerpt is from People v. Verkade, D064499 (Cal. App. 2015):

When such documents are subpoenaed, as in the present case, an in camera hearing may be required to determine whether the defendant's need for the information outweighs the third-party's interest in confidentiality. (Pennsylvania v. Ritchie (1987) 480 U.S. 39, 60 [state statute providing for confidentiality of investigative files concerning child abuse]; see Pen. Code, 1326, subd. (c) ["court may order an in camera hearing to determine whether or not the defense is entitled to receive the documents"].) Hammon is quite clear, however. This in camera review is to occur, if at all, at trial not during pretrial proceedings:

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