New Hampshire v. King
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After a jury trial, Defendant Horace King was convicted on two counts of aggravated felonious sexual assault. On appeal to the Supreme Court, Defendant argued that the trial court erred in denying his supplemental motion for in camera review of the victim's medical and counseling records. The trial court found that Defendant "failed to articulate how the requested medical records would be material to his defense." Upon review, the Supreme Court concluded that the trial court's record did not support its conclusion that the records were not material to Defendant's defense: "Defendant presented specific arguments to carry his burden... [the victim's] prior false allegation of sexual assault, her 'tendency to lie,' and the potential effects her ADD and ODD medical and counseling records may have on her competency as a witness." The Supreme Court reversed the trial court's ruling and remanded the case for further proceedings.
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