Was the court's refusal to allow Rizzo access to Dr. Pucci's clinical files a violation of his constitutional rights under the Sixth Amendment Compulsory Process clause and the Fourteenth Amendment Due Process Clause?

Question

Parents of a 14-year-old "Daphne" asked a neighbor and family friend, Joseph Rizzo, who previously helped them with marital problems, to counsel their daughter about her personal and disciplinary problems. Some months later "Daphne" told her parents that Rizzo touched her inappropriately during their counseling sessions; the sessions were immediately cancelled. "Daphne" was then counseled by Dr. Linda Pucci, a clinical psychologist and "Daphne" told Dr. Pucci that an adult had been "messing with her" but did not disclose further details. Police were notified; Rizzo was convicted of several counts of sexually assaulting a child. Before trial, Rizzo motioned the trial court to conduct an in camera review of Dr. Pucci's reports and records. The State provided a six-page summary prepared by Dr. Pucci, explaining her knowledge of the case and treatment of Daphne. Her summary and testimony related to providing reasons why a molested person would be reluctant to come forward. The trial court conducted an in camera review of the records to determine if they contained exculpatory information. After reviewing the records, the trial judge denied Rizzo access to them. He said that Dr. Pucci's files contained the same information as her summary.
What will be an ideal response?

Answer 1

No

Under Pennsylvania v. Ritchie (1987) the Supreme Court held that fundamental fairness required that a father charged with sexually assaulting his 13-year-old daughter receive an in camera review of the records maintained by a child protective agency concerning his daughter, to determine whether they contained exculpatory information or information that would affect the outcome of the trial. Under the Fourteenth Amendment the government must turn over evidence in its possession that is both favorable to the accused and material to guilt or punishment. However, full disclosure to defense counsel in this type of case would unnecessarily sacrifice the State's compelling interest in protecting its child-abuse information. An in camera review by the trial court balances the rights of the defendant in ensuring a fair trial and the needs of the State or the individual to keep those records private. Rizzo received the same procedure as did Richie