Milstead v. Johnson

KERN, Justice.

[¶ 1.] Defendant was arrested, and charged with several offenses, including two counts of simple assault against a law enforcement officer. Defendant served a subpoena duces tecum on the county sheriff requesting “[a]ll disciplinary records/reports, disciplinary actions or complaints” contained within the personnel files of three Minnehaha County Sheriff Department detectives. The sheriff filed a motion to quash the subpoena, which the circuit court- denied in part. The court ordered the sheriff to produce, for in -camera review, complaints against one of the officers “for…