State of Minnesota v. Melvin Eugene Snoddy
A15-1525
| Minn. Ct. App. | Nov 21, 2016Background
- Victim L.J., age seven, alleged that appellant Melvin Snoddy touched her vagina at his home after a relative's party; Snoddy denied sexual contact.
- L.J. later reported the incident to her grandmother, who sought medical and forensic services and reported to police; Snoddy was charged with second-degree criminal sexual conduct.
- An in camera review of child-protection records produced a single page noting L.J. “has a mental health diagnosis of schizoaffective disorder.”
- Four days before trial, Snoddy sought judicial subpoenas for L.J.’s medical records to impeach her credibility based on that alleged diagnosis; the district court denied the request.
- The district court conducted a competency hearing and found L.J. competent; at trial the defense pursued an impeachment theory that L.J. was a liar and inconsistent; a jury convicted Snoddy.
- On appeal, Snoddy argued the court abused its discretion by denying access to the medical records; the Court of Appeals affirmed.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Snoddy) | Held |
|---|---|---|---|
| Whether defendant was entitled to in camera review/ judicial subpoenas for victim’s medical records | District court properly required a showing before invading medical privacy and denied subpoena as defendant failed to meet standard | Medical records could show schizoaffective-related delusions affecting witness credibility; defendant made sufficient showing to justify review | Affirmed: defendant failed to show records were likely material and favorable; denial of subpoenas not an abuse of discretion |
| Whether an isolated nonmedical record reference to a diagnosis justifies compelled medical record review | A bare reference does not plausibly show material evidence exists in medical files | The child-protection note referencing schizoaffective disorder justified further review to test witness credibility | Held for State: isolated reference insufficient to meet Hummel/Evans threshold |
| Whether diagnosis evidence would be more probative than prejudicial | Court correctly found diagnosis evidence potentially unfairly prejudicial and not directly relevant without proper foundation | Diagnosis could be probative of truthfulness and thus relevant to impeachment | Court: diagnosis alone is not admissible; impeachment must follow rules (e.g., Rule 608) and diagnosis would likely be more prejudicial than probative |
| Whether defendant’s request was untimely | Timeliness and prior continuances supported denial | Defense argued need to inspect records outweighed timing concerns | Court: untimely request supported denial along with failure to show materiality |
Key Cases Cited
- State v. Evans, 756 N.W.2d 854 (Minn. 2008) (defendant must make a plausible showing that medical records may contain material, favorable evidence; court may perform in camera review)
- State v. Hummel, 483 N.W.2d 68 (Minn. 1992) (prerequisites for judicial review of confidential files require a showing of materiality)
- State v. Kutchara, 350 N.W.2d 924 (Minn. 1984) (medical privilege may yield to defendant’s confrontation right in limited circumstances)
- State v. Paradee, 403 N.W.2d 640 (Minn. 1987) (balancing privacy interest against defendant’s need for evidence)
- State v. Wildenberg, 573 N.W.2d 692 (Minn. 1998) (definition of materiality: reasonable probability disclosure would change outcome)
- United States v. Bagley, 473 U.S. 667 (1985) (exculpatory evidence is material when there is a reasonable probability its disclosure would have affected trial outcome)