Booth v. State
2011 Alas. App. LEXIS 29
Alaska Ct. App.2011Background
- Booth was charged with fourth-degree assault of his wife, fourth-degree assault on Officer Bailey, and resisting arrest after officers used pepper spray and restrained him during an arrest.
- Booth sought pre-trial disclosure or in camera review of Officers Bailey and Griffith's personnel files for prior excessive-force complaints, disciplinary actions, or pepper-spray training information.
- The district court denied both disclosure and in camera review requests, finding no basis to inspect the files.
- At trial, Booth argued Griffith used excessive force and that the officers fabricated or exaggerated claims that Booth assaulted Bailey and resisted arrest.
- The jury convicted Booth of assaulting his wife and assaulting Bailey, but acquitted him of resisting arrest.
- On appeal, Booth challenged the district court’s denial of in camera review of the officers’ personnel files.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper standard of review for discovery rulings | Booth contends abuse of discretion governs. | State asserts de novo review is inappropriate. | De novo review applies; not abuse of discretion. |
| Threshold for in camera review of police personnel files | If information could be relevant to guilt/innocence, in camera review is warranted. | No showing of potential relevance; should not inspect. | A good-faith factual predicate allowing potential relevance entitles in camera inspection. |
| Booth's entitlement to in camera review of Griffith file versus Bailey file | Griffith's file may contain relevant excessive-force history or training data. | No sufficient link to Booth’s defense for Bailey’s file. | Entitled to in camera review of Griffith’s file; Bailey’s file not shown to meet threshold. |
| Disclosure of training records | Griffith’s training on pepper spray could reveal motive to lie. | No direct link established to Booth's defense. | District court should examine Griffith's training records in camera for relevant information. |
Key Cases Cited
- Dana v. State, 623 P.2d 348 (Alaska App. 1981) (establishes Dana threshold for in camera review of police personnel files)
- Gissendanner, 399 N.E.2d 924 (N.Y. 1979) (defines relevance and materiality limits for disclosure of personnel records)
- March v. State, 859 P.2d 714 (Alaska App. 1993) (requires in camera review when materials may lead to favorable evidence)
- Jones v. Jennings, 788 P.2d 732 (Alaska 1990) (discovery issues discussed in context of pre-trial materiality)
- Cockerham v. State, 933 P.2d 537 (Alaska 1997) (endorses Dana/Gissendanner approach to confidentiality and discovery)
- State v. Blackwell, 845 P.2d 1017 (Wash. 1993) (requires factual predicate showing materials may bear information material to defense)