People v. Sauls

This case presents question in prosecution on charge of predatory criminal sexual assault of child as to whether trial court erred in quashing defendant’s subpoena requesting records from Department of Children and Family Services (DCFS) without first reviewing requested material in camera. Appellate Court found that trial court did not abuse its discretion in quashing instant subpoena, since defendant had failed to establish basis for his claim that subject unfounded report by DCFS contained material evidence. In his petition for leave to appeal, defendant argued that under Escareno, 2013 IL App (1st) 110152, he was entitled to in camera review of subpoenaed documents for materiality, and that he was entitled to remand for such review, if, as here, trial court had refused to conduct in camera review of subpoenaed documents.