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The supreme court has explained that “it is within the trial court’s discretion to admit photographs, even ghastly ones, so long as they show something that a witness could describe and are material to some relevant issue.” State v. Hummel , (affirming admission of multiple photos showing murder victim covered in blood because the photos “allowed the jury to better visualize the crime scene” and “the extent and type of harm to the victim is material to the issues of intent and premeditation”).

“Under the fourth amendment, warrantless searches and seizures are per se unreasonable unless they fall under an established exception.” (emphasis omitted) (citing Katz v. United States, 389 U.S. 347, 357 (1967)).

A defendant is not entitled to in camera review of confidential records; instead, the defendant generally must make a “plausible showing” that the records sought will be “both material and favorable to his defense.” (quotations omitted).

In-camera review of confidential records is a discovery option, not a right; thus, a defendant must make a “plausible showing” that the records sought will be both “material and favorable to his defense.” (quotations omitted).

In those cases, we have required “some plausible showing that the information sought would be both material and favorable to his defense.” (citation omitted) (internal quotation marks omitted); –73 (Minn. 2008).

In doing so, Wenzel makes several arguments regarding whether he made a “plausible showing” that I.M.’s medical records contained information “material and favorable to his defense.” (quotation omitted).

In camera review of confidential records is a discovery option, not a right; thus, a defendant must make a “plausible showing” that the records sought will be both “material and favorable to his defense.” (quotations omitted).

Warrantless searches and seizures are generally unreasonable, and evidence obtained during a warrantless search is inadmissible at trial unless an exception to the warrant requirement applies, State v. Hummel

We are not persuaded otherwise by Ramirez’s assertion, that the supreme court has recognized that medical and mental-health records protected by paragraphs (d) and (g) may be ordered disclosed in a criminal prosecution when the defendant has made a threshold showing that the records are likely to contain favorable information.

Because in camera review is a discovery option, and not a right, a defendant must make a “plausible showing” that the records sought will be both “material and favorable to his defense.” (quotations omitted).

See Hahn, d at 33 (“[P]hotographs are not rendered inadmissible just because they vividly depict a shocking crime or incidentally tend to arouse the passions and prejudices of the jurors.” (quotation omitted)); (concluding that the district court has discretion over the admission of relevant photographs); (stating that a photograph’s graphic nature cannot be the only reason for excluding it from evidence).

In camera review is not a right but rather a discovery option, and the defendant must first make a “plausible showing” that “the information sought would be both material and favorable to his defense.” (quotations omitted).

“If a warrantless search does not fall within a proper exception, its fruits must be suppressed.”

11 Yildirim counters that he need only make the “plausible showing” required by our decisions in State v. Paradee , and State v. Hummel , to extract the cell phone data and provide it to the court for in camera review, and that by doing so , compliance with a subpoena cannot be unreasonable.

2(c); (recognizing that rules permit defendant to request subpoena of psychological records in possession of third party).

A party requesting in -camera review must make a “plausible showing that the information sought would be both material and favorable to his defense.” -72 (Minn. 1992).

seizures are ‘per se unreasonable unless they fall under an established exception’ to the warrant requirement.” ().

See State v. Hummel , -72 (Minn. 1992) (holding that a person requesting in camera review must make a “plausible showin g that the information sought would be both material and favorable to his defense”).

In support of his request, he relies on two cases, both of which arose in the context of how to treat privileged and confidential material.

To obtain in camera review, the defendant first must make a “plausible showing that the information sought would be both material and favorable to his defense.” (quotation omitted).