State v. Shannon

McCULLOUGH, Judge,

concurring in part and dissenting in part.

I concur in so much of the majority opinion that concludes that the trial of this defendant was conducted free of error.

I dissent from the majority’s remand for an evidentiary hearing to determine if the prosecutor’s failure to memorialize his conversation with Daisy Shannon resulted in prejudice.

The discovery statute at issue, N.C. Gen. Stat. § 15A-903(a)(l) (2005) does broaden the defendant’s right to have all of witness’s statements made to an investigator, whether or not adopted by that *364witness. The statute makes the complete files of all law enforcement and prosecutorial agencies involved in the investigation and prosecution of the crime available. A witness’s statement made during the investigation or prosecution must be turned over.

As the majority notes, the work product of the prosecuting attorney is still given protection, however. The pertinent statute states: “The State is not required to disclose written materials drafted by the prosecuting attorney or the prosecuting attorney’s legal staff for their own use at trial, including witness examinations, voir dire questions, opening statements, and closing arguments.” N.C. Gen. Stat. § 15A-904(a) (2005) (emphasis added). It is our duty to reconcile both statutes and give meaning to each, if possible.

In the case at bar the Assistant District Attorney stated that he would have provided the defense with any exculpatory material had there been any, but only made notes to assist him in questioning the witness.

The majority evidently agrees that when a prosecutor writes down the questions he or she intends to ask the witness, that constitutes his or her “work product” and is protected pursuant to N.C. Gen. Stat. § 15A-904. Such writings are “materials drafted by the prosecuting attorney . . . for their own use at trial, including witness examinations . ...” Id. Such questions necessarily reveal the prosecutor’s “opinions,” “strategies,” “theories,” or “conclusions,” all of which are similarly protected. Id.

In the majority view this does not relieve the prosecutor of his or her duty under N.C. Gen. Stat. § 15A-903 regarding the memorialization of a witness’s “oral statements.” To meet this obligation the prosecutor must either tape-record his witnesses’ responses or prepare a written summary of those responses.

To follow the majority’s logic, when a prosecutor meets with a witness and asks the witness questions, prepares the witness, and records his intended questions for that witness, he or she must simultaneously prepare a written or tape-recorded copy of the witness’s responses for production to the defense. That would leave no protection for the prosecutor’s “work product.”

This rule places an unnecessary burden on the prosecutor, for it would apply to every witness the prosecutor interviews prior to trial, not just those who, like Daisy Shannon, had never been previously interviewed.

*365I do not believe the legislature intended to place such a huge, redundant administrative burden on the District Attorney, nor do I believe the legislature intended to so thoroughly eviscerate the prosecutor’s “work product” exclusion.

Thus, I dissent.