State v. Martinez, 212 N.C. App. 661 (Jun. 21, 2011)

In a child sex case, the trial court erred by failing to require disclosure of material exculpatory information contained in privileged documents that were reviewed in camera by the trial court and pertained to the victim’s allegations. The documents contained “sufficient exculpatory material to impeach the State’s witnesses.” The court instructed the trial judge to “review the material de novo to determine, in his or her discretion, what material should be made available to Defendant.”