Coachman v. State
In Coachman v. State, 692 S.W.2d 940 (Tex.App.--Houston 1st Dist. 1985, pet. ref'd), the defendant was convicted of aggravated sexual assault of a child.
On direct appeal, he challenged the trial court's refusal to permit his attorney to review the entire file from Children's Protective Services.
Coachman contended that he was entitled to discover the name of the person who filed the report and he was thus thwarted in his attempt to find potential witnesses. The trial court required the prosecution to identify all of the State's witnesses to be called at trial.
The defense was also able to elicit testimony revealing the name of the reporter. Because Coachman made no showing of prejudice or necessity, the appellate court concluded that the confidential nature of child abuse reports should be maintained.