Pennsylvania v. Ritchie
United States Supreme Court
480 U.S. 39 (1987)
Charged with repeatedly sexually assaulting his 13-year-old daughter, George Ritchie (defendant) sought all Children and Youth Services (CYS) records related to the investigation, including a recorded interview of his daughter, but CYS refused based on a Pennsylvania confidentiality statute permitting disclosure only by court order; the trial judge denied Ritchie's request without personally reviewing the file, his daughter was cross-examined at trial, and Ritchie was convicted on all charges. The Pennsylvania Superior Court found the non-disclosure violated Ritchie's cross-examination rights and ordered a new trial unless the error was harmless, and the Pennsylvania Supreme Court affirmed while further ordering that Ritchie himself, not just the court, was entitled to review the entire CYS file under both the Confrontation and Compulsory Process Clauses; the U.S. Supreme Court granted certiorari.
Whether the Sixth Amendment's Confrontation Clause or Compulsory Process Clause entitles a criminal defendant to pretrial access to confidential government records that might contain exculpatory evidence or witness information, and if not, what standard governs the defendant's right to that material.