IN THE DISTRICT COURT FOR THE FIFTIETH JUDICIAL DISTRICT
PARISH OF PEINE DE MORT
STATE OF LOUISIANA

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STATE OF LOUISIANA
v.
JOHN CLIENT
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MOTION TO REVEAL LAW ENFORCEMENT REPORTS

COMES NOW, JOHN CLIENT, by counsel, and moves this Court pursuant to the Fourth, Fifth, Sixth, Eighth and Fourteenth Amendments to the United States Constitution, and Article 1, Sections 2, 3, 5, 13, 14, 16 & 17 of the Louisiana Constitution to order the prosecution to reveal law enforcement reports. In support of his motion, John Client states as follows:

1. There is no dispute but that law enforcement reports should be revealed to the defense. In another capital case, State v. Ward, 483 So. 2d 578 (La. 1986), the Louisiana Supreme Court observed that "initial police reports are public records." Id. at 583 (citing State v. Shropshire, 471 So. 2d 707 (La. 1985)). Indeed, this rule is important. For example, in State v. Smith, 594 So. 2d 467 (La. App. 4th Cir. 1992), writ denied, 600 So. 2d 676 (La. 1992), the Court held that "[t]he police report does contain information which contradicts the trial testimony of Officer Vallecillo." Id. at 472. Because the defense was unable to impeach the officer with the report, the conviction was reversed.
2. The same is true of all police reports, whether they be from state law enforcement agents or federal agents. All such reports should be revealed to the defense.
WHEREFORE, the defendant respectfully requests that this Court set his motion down for an evidentiary hearing, and that this Court issue an order requiring the state to reveal any police reports.
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