Cited by
Opinions in Minnesota that cite State v. Paradee, 403 N.W.2d 640.
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State v. Hokanson
821 N.W.2d 340
Minn. 2012
The State responded that the information requested was privileged under the child protection statutes and the Minnesota Government Data Practices Act, and that disclosure was not appropriate without an in camera review and a
- State v. Evans 756 N.W.2d 854 Minn. 2008
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State v. Evans
756 N.W.2d 854
Minn. 2008
This approach “strikes a fairer balance between the interest of the privilege holder in having his confidences kept and the interest of the criminal defendant in obtaining all relevant evidence that might help in his defense.”
- State v. Underdahl 749 N.W.2d 117 Minn. Ct. App. 2008
- State v. Underdahl 749 N.W.2d 117 Minn. Ct. App. 2008
- State v. Burrell 697 N.W.2d 579 Minn. 2005
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State v. Burrell
697 N.W.2d 579
Minn. 2005
18 For instance, in State v. Paradee, which involved a criminal defendant’s request for confidential medical records, we held that in camera review was preferable to an “approach which in effect allows defense counsel easy access to various types of privileged and confidential records simply by asserting that the records might contain material relevant to the *605 defense.”
- State v. Reese 692 N.W.2d 736 Minn. 2005
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State v. Reese
692 N.W.2d 736
Minn. 2005
“The in camera approach strikes a fairer balance between the interest of the privilege holder in having his confidences kept and the interest of the criminal defendant in obtaining all relevant evidence that might help in his defense.” -72 (Minn.1992) ().
- State v. Kramer 668 N.W.2d 32 Minn. Ct. App. 2003
- State v. Kramer 668 N.W.2d 32 Minn. Ct. App. 2003
- State v. Bakken 604 N.W.2d 106 Minn. Ct. App. 2000
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State v. Bakken
604 N.W.2d 106
Minn. Ct. App. 2000
A trial court’s : [I]n camera [review] strikes a fairer balance between the interest of the privilege holder in having his confidences kept and the interest of the criminal defendant in obtaining all relevant evidence that might help in his defense.
- State v. Davis 592 N.W.2d 457 Minn. 1999
- State v. Davis 592 N.W.2d 457 Minn. 1999
- State v. Wildenberg 573 N.W.2d 692 Minn. 1998
- State v. Wildenberg 573 N.W.2d 692 Minn. 1998
- State v. Renneke 563 N.W.2d 335 Minn. Ct. App. 1997
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State v. Renneke
563 N.W.2d 335
Minn. Ct. App. 1997
: The in camera approach strikes a fairer balance between the interest of the privilege holder in having his confidences kept and the interest of the criminal defendant in obtaining all relevant evidence that might help in his defense.
- State v. Turner 550 N.W.2d 622 Minn. 1996
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State v. Turner
550 N.W.2d 622
Minn. 1996
(defendant’s request for in camera review of mental health records was properly denied by district court due to defendant’s failure to show how records could be rele vant to his defense); (in camera review of welfare department records ordered); (while privilege not to disclose past medical records must sometimes give way to defendant’s right to confront his accusers, in camera review of medical records by district court did not reveal
- State v. Enger 539 N.W.2d 259 Minn. Ct. App. 1995
- State v. Knutson 539 N.W.2d 254 Minn. Ct. App. 1995
- State v. Enger 539 N.W.2d 259 Minn. Ct. App. 1995
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State v. Knutson
539 N.W.2d 254
Minn. Ct. App. 1995
(reversing decision that defense counsel be given access to victim’s medical records and remanding for in camera review of the records).
- State v. Logan 535 N.W.2d 320 Minn. 1995
- State v. Logan 535 N.W.2d 320 Minn. 1995
- State v. Goldenstein 505 N.W.2d 332 Minn. Ct. App. 1993
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State v. Goldenstein
505 N.W.2d 332
Minn. Ct. App. 1993
the trial court conducted in camera review of the child protection records that predate the children’s placement in appellants’ home, and contain information about the biological family and the history of maltreatment.
- State v. Brenner 488 N.W.2d 339 Minn. Ct. App. 1992
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State v. Brenner
488 N.W.2d 339
Minn. Ct. App. 1992
See, (access to *341 county welfare confidential records); (access to patient’s medical records).
- State v. Schmid 487 N.W.2d 539 Minn. Ct. App. 1992
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State v. Schmid
487 N.W.2d 539
Minn. Ct. App. 1992
the Minnesota Supreme Court held that under Ritchie , the defendant, who had moved for discovery of county human services and welfare department records, was not entitled to access, but that the trial court was required to examine the records in camera.
- State v. Hummel 483 N.W.2d 68 Minn. 1992
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State v. Hummel
483 N.W.2d 68
Minn. 1992
(adopting the Ritchie analysis for child welfare reports in criminal sexual conduct case).
- St. Peter Herald v. City of St. Peter 481 N.W.2d 405 Minn. Ct. App. 1992
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St. Peter Herald v. City of St. Peter
481 N.W.2d 405
Minn. Ct. App. 1992
which stated that the trial court need not allow counsel to participate in an in camera review of privileged evidentiary material.
- State v. Morgan 477 N.W.2d 527 Minn. Ct. App. 1991
- State v. Morgan 477 N.W.2d 527 Minn. Ct. App. 1991
- State v. Lynch 443 N.W.2d 848 Minn. Ct. App. 1989
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State v. Lynch
443 N.W.2d 848
Minn. Ct. App. 1989
The rules of criminal procedure allow for broad discovery, but they require that the requested documents “relate to the guilt or innocence of the defendant or negate the guilt or reduce the culpability of the defendant as to the offense charged.” Minn.R.Crim.P.
- Erickson v. MacArthur 414 N.W.2d 406 Minn. 1987
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Erickson v. MacArthur
414 N.W.2d 406
Minn. 1987
We have embraced the in camera approach in a criminal defendant’s
- State v. Axford 409 N.W.2d 893 Minn. Ct. App. 1987
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State v. Axford
409 N.W.2d 893
Minn. Ct. App. 1987
That decision was recently reversed, however