## Facts

- George F. Ritchie was charged in Pennsylvania state court with rape, involuntary deviate sexual intercourse, incest, and corruption of a minor based on alleged sexual abuse of his minor daughter.
- The allegations were reported to a county child-protective agency, Children and Youth Services (CYS), which investigated suspected child mistreatment and neglect.
- Before trial, Ritchie subpoenaed CYS records concerning (1) the investigation underlying the charges and (2) earlier CYS investigations involving his children.
- CYS refused to produce the file under a state confidentiality statute permitting disclosure only in limited circumstances, including pursuant to a court order.
- At an in-chambers hearing, Ritchie argued the file might contain favorable witnesses’ names and other exculpatory material; the trial court denied disclosure without a full in camera inspection.
- At trial, the daughter was the principal witness and was cross-examined extensively; Ritchie was convicted by a jury.

## Issues

1. Whether the U.S. Supreme Court had jurisdiction to review a state judgment vacating a conviction and remanding, where the federal constitutional question had been conclusively decided.
2. Whether nondisclosure of the CYS file violated the Sixth Amendment Confrontation Clause.
3. Whether the Sixth Amendment Compulsory Process Clause and Fourteenth Amendment due process required access to confidential CYS records, and if so, what procedure was constitutionally required.

## Decision

- The Court held it had jurisdiction because the state court had finally resolved the federal issue in a way that would govern further proceedings and evade later review.
- A plurality concluded the Confrontation Clause was not violated because it is principally a trial right guaranteeing an opportunity for effective cross-examination, not a pretrial discovery entitlement, and the complainant was cross-examined at length.
- The Court held due process required the trial court to review the CYS file in camera and disclose evidence that is both favorable to the defense and material to guilt or punishment.
- The Court rejected a constitutional right for the defendant or defense counsel to inspect the entire confidential file.
- The judgment was affirmed in part, reversed in part, and remanded for in camera review and disclosure of any material, favorable information.

## Legal Principles

- A state-court decision may be sufficiently final for Supreme Court review when it conclusively decides a federal question that will control subsequent proceedings and cannot effectively be reviewed later, regardless of the eventual outcome.
- The Confrontation Clause is a trial guarantee of effective cross-examination and does not itself create a general pretrial right to obtain confidential third-party records.
- Due process requires disclosure of evidence favorable to the accused when it is material; for confidential third-party records, this obligation may be satisfied through judicial in camera inspection rather than full defense access.
- In camera review by the trial court is an accepted method to reconcile the defendant’s right to a fair trial with strong confidentiality interests in sensitive child-protective records, where state law permits court-ordered access.
- The constitutional requirement is limited to disclosure of material, favorable information; it does not compel unrestricted disclosure of protected files.

## Conclusion

The Court ruled that the defendant was not entitled to pretrial discovery of confidential child-protective records under the Confrontation Clause, but due process required the trial court to examine the records in camera and disclose any information that was favorable and material to the defense, while preserving statutory confidentiality beyond that limit.


Pennsylvania v. Ritchie, 480 U.S. 39 (1987)