Gunnerud v. State

In Gunnerud v. State, 611 P.2d 69 (Alaska 1980), the Alaska Supreme Court approved a trial judge's decision to conduct an in camera review of a psychiatric report concerning a government witness, to see if the report contained information that was relevant to assessing the witness's credibility. The trial judge in Gunnerud examined the psychiatric report, concluded that it had no relevance to the witness's credibility, and therefore refused to disclose the report to the defense. The supreme court upheld the trial judge's decision -- but the implication of Gunnerud is that the trial judge would properly have disclosed the psychiatric report to the defense if the judge had concluded that the report was relevant to assessing the witness's credibility.