State v. Scott, 1 CA-CR 15-0382

Defendant Daniel Vernon Scott was tried for offenses arising from a May 3, 2014 physical altercation with his wife, J.S.; jury convicted him of the lesser included offense: disorderly conduct with a deadly weapon (domestic violence related).
Victim J.S. has a diagnosis of paranoid schizophrenia, takes medication, and admitted prior commitment, memory issues, and a prior aggravated-assault arrest involving Scott.
Scott claimed self-defense and sought pretrial production of ten years of the victim’s mental-health records (including VA records) for in camera review to impeach/perception evidence.
The superior court denied the motion, citing Victims’ Bill of Rights protections and lack of demonstrated constitutional need; it did order disclosure of any medical records in the victim’s possession from two months before the incident through the date of the incident.
Scott also sought admission of the victim’s prior interactions with law enforcement (2006–2013); the court admitted only the 2013 aggravated-assault arrest directed at Scott and excluded other past incidents as irrelevant or prejudicial.
On appeal, Scott argued the court erred in both rulings; the Court of Appeals affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Scott)	Held
Denial of compelled production of ten years of victim’s mental-health records	Victim’s privacy and statutory protections outweigh speculative defense need; records protected	Records likely contain impeachment/exculpatory material essential to self-defense and due process; in camera review required	Affirmed: defendant failed to show a substantial, constitutional need; Victims’ Bill of Rights and lack of showing made denial proper; court balanced interests and allowed limited discovery close in time to incident
Exclusion of other-act evidence of victim’s prior law-enforcement interactions	Many prior incidents were collateral, remote, non-violent, and unduly prejudicial	Prior incidents show victim’s violent tendencies and were known to defendant, relevant to his state of mind for self-defense	Affirmed: court properly admitted only the 2013 aggravated-assault arrest directed at Scott; other incidents were irrelevant or unduly prejudicial under Rules 403/404(b)

State v. Connor, 215 Ariz. 553 (App. 2007) (requires demonstrable "substantial need" of constitutional dimension to overcome victim privacy/privilege)
State ex rel. Romley v. Superior Court (Roper), 172 Ariz. 232 (App. 1992) (balance defendant’s rights against victim privacy may permit disclosure in some cases)
State v. Sarullo, 219 Ariz. 431 (App. 2008) (Victims’ Bill of Rights gives victim right to refuse medical-record disclosure)
State v. Hatton, 116 Ariz. 142 (1977) (mere conjecture that records might be useful is insufficient to compel disclosure)
State v. Fish, 222 Ariz. 109 (App. 2009) (Rule 404(b) framework and Rule 403 balancing for other-act evidence)
State v. Santanna, 153 Ariz. 147 (1987) (prior violent acts known to defendant admissible to show state of mind for self-defense)
State v. Zamora, 140 Ariz. 338 (App. 1984) (admissibility limits for other acts: must be known to defendant or closely related in time/circumstance)
State v. Carlson, 237 Ariz. 381 (2015) (appellate courts may affirm on any correct basis presented)