Crawford v. State

SULLIVAN, Justice.

In In re Subpoena to Crisis Connection, Inc., No. 19S05-1012-CR-678, 949 N.E.2d 789 (Ind.2011), another case handed down today, we hold that the three-step test for the discoverability of information outlined in State v. Cline (In re WTHR-TV), 693 N.E.2d 1, 6 (Ind.1998), is not reached when information is protected by an unqualified privilege unless a criminal defendant’s constitutional rights would be violated by enforcing the privilege. Because no privilege is at issue in this case, we apply the three-step test and conclude that the defendant has not satisfied the…