State v. Bundy

I

The issue upon which the court of appeals certified this case as a conflict is essentially whether the trial court, to determine the availability of personnel files of a police-officer witness to the parties or their attorneys, must conduct an in camera inspection of the files prior to its ruling.

In Dayton v. Turner (1984), 14 Ohio App. 3d 304, the Court of Appeals for Montgomery County held that “where materials are subpoenaed from the internal affairs division files of a police department, a generalized assertion of privilege on the basis of confidentiality must yield to a demonstrated…