In Pennsylvania v. Ritchie, 480 U.S. 39 (1987), the defendant was charged with committing sexual acts on his daughter. The child's allegations had been investigated by the state's child protective services agency. Before trial, the defendant served the agency with a subpoena requesting the records of its investigation. The trial court rejected the request, but the state supreme court reversed the defendant's conviction in part, finding the trial court order violated the defendant's confrontation rights under the Sixth Amendment. The United States Supreme Court remanded the matter for an in camera review of the records to determine whether, under the Fourteenth Amendment's due process clause and Brady v. Maryland (1963) 373 U.S. 83, they contained evidence material to the issues of guilt or punishment that was favorable to the defendant. (Pennsylvania v. Ritchie, supra, 480 U.S. at pp. 56-57, 59, 61.) In so ruling the Court considered but declined to decide whether the Sixth Amendment's confrontation or compulsory process clauses authorized pretrial disclosure of the child protective service's records. (Pennsylvania v. Ritchie, supra, 480 U.S. at p. 56.) However, the lead opinion, expressing the views of four members of the court, declared "the opinions of this Court show that the right to confrontation is a trial right, designed to prevent improper restrictions on the types of questions that defense counsel may ask during cross-examination. " (Id. at p. 52.) The United States Supreme Court considered the question of whether the Sixth Amendment requires as a pre-trial obligation the disclosure of confidential child protective records to a criminal defendant who was charged by the prosecution with rape and sexual abuse of his minor daughter, the same allegations investigated by child protective services in the State of Pennsylvania. The Court held as follows: "A defendant's right to discover exculpatory evidence does not include the unsupervised authority to search through the Commonwealth's files . . . Although the eye of an advocate may be helpful to a defendant in ferreting out information . . . this Court has never held even in the absence of a statute restricting disclosure that a defendant alone may make the determination as to the materiality of the information" (Pennsylvania v. Ritchie, 480 U.S. at 59.) The Court concluded that the defendant's right to a fair trial "can be protected fully by requiring that the CYS child protective files be submitted only to the trial court for in camera review" (id. at 60). The Court noted that this rule denies the defendant "the benefits of an advocate's eye'" but found that the interests of the State in maintaining the confidentiality of child protective records were compelling: "To allow full disclosure to defense counsel in this type of case would sacrifice unnecessarily the Commonwealth's compelling interest in protecting its child-abuse information. If the CYS child protective records were made available to defendants, even through counsel, it could have a seriously adverse effect on Pennsylvania's efforts to uncover and treat abuse. Child abuse is one of the most difficult crimes to detect and prosecute, in large part because there often are no witnesses except the victim. A child's feelings of vulnerability and guilt and his or her unwillingness to come forward are particularly acute when the abuser is a parent. It therefore is essential that the child have a state-designated person to whom he may turn, and to do so with the assurance of confidentiality" (id.)