State v. Lammi

The state petitions for reconsideration of our decision in State v. Lammi, 278 Or App 690, 375 P3d 547 (2016). For the reasons below, we grant reconsideration and, with the following clarification, adhere to our original opinion and disposition.

Defendant in this case was convicted of multiple sex offenses against his daughter. Id. at 691. During trial, defendant subpoenaed the victim’s counseling records and requested that the trial court conduct an in camera review of those records for exculpatory evidence relevant to the charges against him. Id. at 692. The trial court denied that request…