How have the courts treated a subpoena for in camera review of records submitted to the Court of Appeal?

California, United States of America


The following excerpt is from People v. Conklin, F071447 (Cal. App. 2017):

Appellant contends the trial court's failure to conduct an in camera review of the subpoenaed records violated his Sixth Amendment right to confrontation. He suggests his subpoena was not pretrial discovery, and he argues the failure to maintain a copy of the records violated his due process right to a full appellate record. We disagree. Based on People v. Hammon (1997) 15 Cal.4th 1117 (Hammon), appellant's claim fails.

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