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State v. Graville
Citations: 746 P.2d 715; 304 Or. 424; 1987 Ore. LEXIS 1988Docket: TC 10 84 07904; CA A38105; SC S33503
Court: Oregon Supreme Court; December 8, 1987; Oregon; State Supreme Court
The Oregon Supreme Court reviewed a case concerning the discovery rights of a defendant, Paula Ann Graville, charged with sexual abuse. Graville sought access to the Children's Services Division (CSD) files related to the child victim, claiming this was necessary under Brady v. Maryland and Wardius v. Oregon, which address the federal due process clause. The prosecutor reviewed the file and found no exculpatory material, leading the trial court to deny Graville's discovery request. Upon appeal, the Court of Appeals reversed the trial court's decision, mandating an in camera inspection of the CSD files. The Supreme Court affirmed this decision, noting that while the defendant's request for the entire file was overly broad, she was entitled to access specific materials through in camera review, particularly under the provisions of ORS 135.815. The court referenced Pennsylvania v. Ritchie, which similarly required in camera reviews of relevant confidential files for exculpatory evidence. The Supreme Court vacated the previous judgment and remanded the case for further proceedings consistent with its opinion, emphasizing the necessity for the trial court to determine if any exculpatory evidence existed that could influence the outcome of the trial. The court did not address whether the Oregon Constitution provided broader rights than the federal due process clause.