Calisto Mariko Wells v. State of Arizona

OPINION

ECKERSTROM, Presiding Judge.

¶ 1 In this special action, petitioner Calisto Wells challenges the respondent judge’s ruling ordering him to disclose police-officer witness statements made during interviews of which the state had no notice, despite his intent to use the statements solely for impeachment. We accept special action jurisdiction to clarify that a trial court may, upon a showing of substantial need and undue hardship, order such materials disclosed. But because our record is unclear whether the state made such a showing here, we vacate the respondent judge’s order.

Background

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