Must the State Produce Its Witnesses' Criminal Records in Discovery?

I've been asked several times whether the state is required to provide the defense with the criminal record of the state's witnesses. There are two possible justifications for such a requirement. First, one could argue that disclosure is mandated by the discovery statutes, G.S. 15A-901 et seq. Second, one could argue that disclosure is required by Brady v. Maryland, 373 U.S. 83 (1963), which generally holds that the state must produce any exculpatory, mitigating, or impeachment evidence to the defense. These arguments have failed to persuade our appellate courts, which have repeatedly held that a defendant is not entitled to this information. See, e.g., State v. Williams, 355 N.C. 501, 543-44 (2002) (citing cases); State v. Bruce, 315 N.C. 273 (1985). I don't think the issue is quite as settled as it seems, though, either as a statutory matter or as a constitutional one. Starting with the statutory analysis, Williams and virtually all the other cases in this area were decided before the enactment of open file discovery in 2004. S.L. 2004-154. Under the new version of G.S. 15A-903, the state must produce "the complete files of all law enforcement and prosecutorial agencies" involved in the case. Based on that language, when a witness's record has been printed out or otherwise made part of the case file, it must be produced in discovery. Moving to the constitutional issue, the reason why many courts have held that the state is not required to produce its' witnesses' criminal records is that those records [...]