Crawford v. State
Annotate this CaseAppellant Lamar Crawford was convicted of murder. Prior to his trial, a television production company called Lucky Shift, Inc. filmed aspects of Crawford's murder investigation and interviewed people involved. Crawford requested an order for the trial court directing Lucky Shift to produce the footage. The trial court ordered many items requested by Crawford be disclosed for an in camera review but denied three of Crawford's requests because they were not particular enough. Appellant appealed the denial. The court of appeals affirmed the ruling that the three requests were not sufficiently particular under the three-step test used to determine the discoverability of information not otherwise protected by privilege in criminal cases set forth in State v. Cline. On transfer, the Supreme Court repeated the three-step test and found that Crawford's requests were not made with sufficient particularity. The Court therefore affirmed the judgment of the trial court.
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