State v. Johnson

Respondent, Jonathan Johnson, was convicted of sexual abuse of a minor and second-degree sexual offense. Leading up to trial, Respondent sought, by means of a trial subpoena, access to the minor victim’s mental health records. The trial court denied Respondent’s request for an in camera review of those records, reasoning that his request amounted to a “fishing expedition,” and concluding that Respondent did not show a reasonable likelihood that the records contained exculpatory evidence as required by Goldsmith v. State, 337 Md. 112, 651 A.2d 866 (1995). In Goldsmith, this Court rejected the…