OR: CI privilege doesn’t require production of CI for in camera review if there is PC

While “Defendant does not challenge the trial court’s further determination that the affidavit contained sufficient information to establish the CI’s reliability and credibility,” he faults the trial court for not having the CI produced for in camera review. The identity of the CI is privileged unless he or she is a material witness, and the trial court didn’t err in denying this discovery request. State v. Robertson, 289 Ore. App. 703, 2018 Ore. App. LEXIS 35 (Jan. 5, 2018).

Defendant’s furtive movements in the car around the console justified a protective frisk of the car for weapons. People v. Colon, 2018 NY Slip Op 00062, 2018 N.Y. App. Div. LEXIS 68 (1st Dept. Jan. 4, 2018).*

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