Henneman v. Toledo

DOUGLAS, J. The principal question posed by this appeal is whether information and records compiled by a police department pursuant to
its internal investigation of alleged police misconduct are subject to an executive privilege, either qualified or absolute,
protecting such information and records from the normal discovery requirements of civil litigation. We hold that such evidence
must be disclosed upon a proper discovery request if, pursuant to an in camera inspection, the trial judge determines that
the public interest in the confidentiality of such information is outweighed by the litigant's specific need for the evidence.