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In United States v. Arias, the Eighth Circuit ordered documents to be produced on the basis of the Confrontation Clause. Despite creating a circuit split, in this article Ryan Gallagher argues that the holding is correct.
Arias, Confrontation clause, sixth amendment, document, request, production
Gallagher, Ryan, "United States v. Arias: Can the Confrontation Clause Compel Discovery?" (2020). SLU Law Journal Online. 56.