Crawford v. State, 2011 Ind. LEXIS 516

Crawford was convicted of murder; private production company Lucky Shift filmed the investigation and produced The Shift episode.
Crawford sought production of footage from Lucky Shift related to the investigation; the trial court granted some items and denied three for lack of particularity.
Court of Appeals affirmed denial, holding the three requests lacked sufficient particularity under the three-step discovery test.
Crawford sought transfer; Indiana Rules govern criminal discovery and the three-step test: particularity, materiality, and paramount interest.
The Supreme Court granted transfer and held requests 18 and 19 were not sufficiently particular; no privilege issue was involved; the court reaffirmed the three-step framework.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Crawford's requests satisfied particularity under the three-step test.	Crawford argues requests are sufficiently particular to identify footage.	Crawford's requests are too broad and vague, effectively a fishing expedition.	No; requests lacked reasonable particularity.
Whether the trial court abused its discretion in quashing the discovery requests.	Discretion should favor broader pre-trial discovery for defense.	Requests are overly broad and would intrude on nonparties without clear specification.	No abuse; court appropriately limited discovery.

In re WTHR-TV, 693 N.E.2d 1 (Ind. 1998) (three-step test for discoverability in criminal cases (particularity, materiality, paramount interest))
WTHR-TV v. Milam, 690 N.E.2d 1174 (Ind. 1998) (illustrates particularity limitations and breadth of discovery requests)
Dillard v. State, 257 Ind. 282, 274 N.E.2d 387 (Ind. 1971) (origin of three-step discovery framework; gatekeeping role of particularity)
State v. Cline (In re WTHR-TV), no separate official reporter provided (Ind. 1989/1998) (foundational case for discovery framework referenced in WTHR cases)