People v. McCray, 23 N.Y.3d 193 (2014)
A trial court does not abuse its discretion by withholding confidential mental health records of a complainant in a rape case if there is no reasonable possibility that disclosing the withheld materials would lead to the defendant’s acquittal.
Summary
McCray was convicted of rape. Prior to trial, he requested the complainant’s mental health records to undermine her credibility. The trial court conducted an in camera review, disclosing some records but withholding others. The New York Court of Appeals upheld the trial court’s decision, finding no abuse of discretion. The Court reasoned that most undisclosed documents were cumulative or irrelevant, and the potential impact of the remaining records, including a past accusation of sexual assault against the complainant’s father, was too remote to warrant disclosure given the complainant’s confidentiality interests. The Court emphasized that the jury was already aware of the complainant’s significant mental health issues.
Facts
McCray and the complainant met in April 2009 and went on a date in May 2009. After visiting friends, they went to an abandoned house. The complainant later called 911, reporting that McCray had beaten and raped her. Police observed blood on her clothes and face, and hospital records confirmed abrasions, bruises, and lacerations. McCray claimed the sex was consensual and that the complainant demanded money afterward, leading to a fight. The complainant had significant mental health issues, including bipolar disorder, Tourette’s, and PTSD, which was disclosed to the jury.
Procedural History
The trial court reviewed the complainant’s mental health records in camera and disclosed 28 pages to the defense, withholding the rest. McCray was convicted of rape. The Appellate Division affirmed the conviction, finding no error in withholding the records. Two dissenting justices argued that the undisclosed records could significantly impact the complainant’s credibility. The Court of Appeals granted leave to appeal.
Issue(s)
Whether the trial court abused its discretion by withholding the complainant’s confidential mental health records after an in camera review, where the defendant argued the records were necessary to challenge the complainant’s credibility.
Holding
No, because the trial court could reasonably conclude that there was no more than a remote possibility that disclosing the withheld records would lead to McCray’s acquittal, outweighing the complainant’s legitimate interest in confidentiality.
Court’s Reasoning
The Court framed the issue as a Brady violation, considering whether the withheld evidence was material. The test of materiality is whether there is a “reasonable possibility” that the verdict would have been different if the evidence had been disclosed. However, because confidential mental health records were involved, the trial court had discretion in deciding whether to disclose them. The Court found most undisclosed documents to be cumulative or of little relevance, as the jury already knew of the complainant’s significant mental health problems. Addressing the undisclosed records of the complainant’s prior accusation of sexual assault against her father, the court acknowledged this gave them some pause. However, it distinguished the prior accusation as being far removed in time and different in nature from the current accusation against McCray. Further, the court noted that there was no indication that the complainant fabricated the accusation against her father. The court concluded that it was almost impossible for a jury to think that the complainant’s accusation in this case was an honest but mistaken one. The court balanced McCray’s interest in obtaining the records against the complainant’s interest in confidentiality, ultimately concluding that the trial court did not abuse its discretion. The court noted, “In sum, the issue here is whether the trial court abused its discretion in finding defendant’s interest in obtaining the records to be outweighed by the complainant’s interest in confidentiality; and defendant’s interest could be outweighed only if there was no reasonable possibility that the withheld materials would lead to his acquittal.”