In a case involving an informant, the trial court ordered production of the informant’s criminal history and all reports of his activity in defendant’s case. However, the court refused to order production of the informant’s activities in unrelated cases and identifying information of unrelated individuals from reports about the informant’s past criminal activities. The court held the limitations on the discovery order were proper. None of the redacted names or identifying information was favorable to defendant. As to the informant’s activities in unrelated cases, the informant had already been extensively cross-examined about his criminal activities and role as an informant in this case, and thus the information in other cases was not material. The withheld material would not have added much, if anything, to defendant’s case.
Case Summaries