The Colorado Supreme Court issued its opinion in In re People v. Angel on May 14, 2012.
Rules of Criminal Procedure—Discovery—Prosecutorial Work Product.
The Supreme Court determined that Crim.P. 16(I)(e)(1) protects against the disclosure of a prosecutor’s opinion work product, and made the rule absolute. The Court reversed the district court’s discovery order and held that the prosecutorial work product exception under Crim.P. 16(I)(e)(1) protects from compelled disclosure all opinion work product prepared by the prosecution in anticipation of any criminal prosecution. The Court remanded the case to the district court to determine, through an in camera, ex parte review, whether the contested materials contain protected prosecutorial opinion work product.
Summary and full case available here.