The District Court has inherent discretionary power to control discovery based on its authority to control trial administration. We review a district court's rulings on discovery motions for an abuse of discretion. The party claiming error in the district court's discovery rulings must show prejudice. Hendricksen v. State, 2004 MT 20, ¶ 35, 319 Mont. 307, 84 P.3d 38.
The in camera procedure should be used to decide what information could be properly discovered. State v. Burns, 253 Mont. 37, 39, 830 P.2d 1318, 1320 (1992) (citing In re Lacy, 239 Mont. 321, 326, 780 P.2d 186, 189 (1989)).
An in camera review is often used at various stages throughout discovery and trial "to balance the privacy interests of the parties and the need to know. The in camera procedure can effectively offer protection to both parties by avoiding needless exposure of potentially harmful information." Hendricksen v. State, 2004 MT 20, ¶ 37, 319 Mont. 307, 84 P.3d 38 (quoting State v. Burns, 253 Mont. 37, 39, 830 P.2d 1318, 1319-20 (1992)).
We review a district court's decision to conduct an in camera inspection of evidence, and its decision whether or not to require disclosure of the reviewed evidence, for an abuse of discretion. State v. Burns, 253 Mont. 37, 42, 830 P.2d 1318, 1322 (1992). State v. Knowles, 2010 MT 186, ¶ 53, 357 Mont. 272, 239 P.3d 129.