State v. R.F.P.

SYLLABUS This syllabus is not part of the Court’s opinion. It has been prepared by the Office of the Clerk for the convenience of the reader. It has been neither reviewed nor approved by the Court and may not summarize all portions of the opinion. State v. R.F.P. (A-5-25) (090566) Argued March 2, 2026 -- Decided July 9, 2026 JUSTICE FASCIALE, writing for the Court. In this appeal, the Court considers whether the trial judge correctly applied the standard set forth in State v. Chambers, 252 N.J. 561 (2023), in granting defendant R.F.P.’s motion for an in camera review of the alleged sexual assault victim’s pre-incident mental health records. In May 2021, “Kim,” the alleged victim, age eighteen, stated that her uncle had sexually assaulted her. Kim was examined by a sexual assault nurse and interviewed by detectives from the Bergen County Prosecutor’s Office. Kim told the detectives that while she was in defendant’s room searching for her cat, defendant kissed her, pushed her onto his bed, and then proceeded to engage in further sexual acts without her consent. Kim reported her medical history as “[a]utism, bipolar I, PTSD, asthma, seizures, hypothyroid, [and] anxiety,” and listed her current medications. A grand jury charged defendant with offenses including sexual assault. According to the defense, Kim gave conflicting accounts of the incident. After learning about Kim’s diagnoses and psychotropic medications, defense counsel retained an investigator to learn whether a connection exists between Kim’s mental illnesses and her ability to perceive, recall, or recount details. After interviewing Kim’s family members, best friend, and boyfriend, the defense filed a motion for an in camera inspection of her pre-incident mental health records. The trial judge considered Kim’s mental illnesses; the list of multiple medications she had been prescribed at the time of the incident, including an antipsychotic; Kim’s statements to the police, including that she had reported rape on “countless occasions”; Kim’s statement to the sexual assault nurse examiner; defendant’s statements; the statements from Kim’s family and friends, which corroborated that Kim had a history of making false accusations of rape and not being truthful; evidence that Kim left a hospital against clinical advice close in time to the incident; Kim’s best friend’s statement that he believed Kim was not taking her medicine; and medical articles indicating that bipolar disorder and PTSD can produce testimonial incapacities and on autism and the ability and tendency to lie. 1  The trial judge ordered that Kim’s pre-incident mental health treatment records, limited to her two most recent hospitalizations, be produced to the trial judge for an in camera review. He stated that the production of mental health records for in camera review does not mean that those records will automatically be disclosed to defendant following such review. The Appellate Division determined that defendant failed to meet the heightened discovery standard established in Chambers and reversed. The Court granted leave to appeal. 261 N.J. 568 (2025). HELD: The trial judge correctly applied Chambers, and, upon review of the record, the Court discerns no abuse of discretion in his finding that defendant made a sufficient showing for the judge to conduct a limited and narrow in camera review. 1. A heightened discovery standard governs a defendant’s motion for pre-incident mental health records from a sexual assault victim. The standard is rigorous due to the need to balance a criminal defendant’s constitutional right to present a complete a defense against the significant privacy interests of sexual assault victims. In Chambers, the Court held that “a defendant is entitled to present a meaningful defense by making a good-faith request for pre-incident mental health records of a sexual assault victim.” 252 N.J. at 589. (p. 17) 2. Chambers requires that victims be given notice and the opportunity to be heard when a defendant files a motion seeking access to pre-incident mental health records. Noting that, here, Kim did not initially receive notice, the Court reminds the State of its duty to provide timely notice to a victim whenever a defendant files a Chambers motion and reminds trial judges to ensure -- at the onset of the hearing -- that the victim has received both notice and an opportunity to oppose the motion, as required by the Crime Victims’ Bill of Rights, N.J.S.A. 52:4B-36(r). (pp. 17-18) 3. The first stage of the Chambers standard requires a defendant to show, by a preponderance of the evidence, that (1) the defendant has “a substantial, particularized need” for the records; (2) “the information sought [therein] is relevant and material;” and (3) “the information is not available through less intrusive means.” Id. at 590. If a defendant satisfies that three-part standard, then the defendant is entitled to have the trial judge conduct an in camera inspection. Id. at 591. During the second stage, the judge must determine whether to “pierce” the applicable mental health privilege, redact the records, and make them available under a protective order. Id. at 592. At issue here is the first stage: whether defendant is entitled to have the trial judge conduct an in camera inspection of the records. (p. 18) 4. “To establish a substantial, particularized need for access to mental health records,” a defendant must make “some evidential showing that connects the alleged mental illness to the victim’s inability to perceive, recall, or recount the events of the alleged assault, or a proclivity to imagine or fabricate them -- the sole 2 permissible purpose for which access may be granted.” Id. at 590. The Court reviews the evidence here in detail and explains that, in its entirety, defendant’s proffered evidence shows: Kim has specific mental illness diagnoses; Kim received treatment for her mental illnesses at several psychiatric facilities; Kim checked out of the most recent facility against medical advice; Kim is prescribed medication for her mental illnesses; Kim may not have been medication-compliant at the time of the alleged assault; Kim’s friends and family describe her as having “a tendency to lie” and as someone who, due to her mental illnesses, may not appreciate the consequences of lying; Kim demonstrated an inability to accurately recount past events; Kim provided conflicting accounts regarding details of the alleged assault; and Kim’s mental illnesses can produce the types of testimonial incapacities she has demonstrated. Collectively, the evidence amounts to more than bald assertions that Kim’s mental illnesses may affect her ability to perceive, recall, or recollect the assault, or a proclivity to fabricate it. Accordingly, defendant established a substantial and particularized need for Kim’s pre-incident mental health records and thereby satisfied the first prong of the Chambers analysis. (pp. 18-28) 5. The second prong requires defendant to prove that the information sought is both relevant and material. Ibid. The central question here is whether defendant reasonably believed that Kim freely and affirmatively consented to engage in sexual activity with him. Because the record shows that information sought from the records may indicate that Kim has a proclivity to imagine or fabricate the alleged assault, the information is relevant and material to defendant’s defense. (pp. 29-31) 6. Under the third prong, defendant must demonstrate by a preponderance of the evidence that the information sought is not available through less intrusive means. Id. at 591. Here, defendant has demonstrated gaps in the evidence as to Kim’s mental illnesses and treatment, and the only way for defendant to reliably obtain such information is through Kim’s pre-incident mental health records. (pp. 31-32) 7. The Court reiterates that this case concerns only the initial stage of the Chambers analysis. The Chambers framework is intentionally structured to impose increasing burdens on defendants as they progress from stage one to stage two, thereby aligning the degree of intrusion with the protection due to the alleged victim’s privacy rights. As the trial judge expressly acknowledged, his preliminary determination to conduct a narrow in camera review does not mean that defendant will automatically be entitled to the mental health records. If, after that review, the judge determines that the records contain relevant material and that the mental health privilege should be pierced, Kim will be afforded an opportunity to challenge those findings. Noting that, under Chambers, requests for an alleged sexual assault victim’s pre-incident mental health records “should remain rare,” id. at 571, the Court finds that this is one such rare case. (pp. 33-35) 3  REVERSED. JUSTICE-PIERRE-LOUIS, dissenting, disagrees with the determination that defendant’s statements are not relevant to whether an in camera review is warranted. Justice Pierre-Louis notes that, when asked by police, “You knew it was not consensual, right?” defendant responded “Yes” and corroborated many details of the incident that Kim reported, yet now moves for access to Kim’s mental health records based on a “good faith” belief that her mental health conditions potentially affect her ability to perceive events and relay information. In Justice Pierre-Louis’s view, the fact that defendant stated in his own words that Kim did not imagine or falsify what transpired during the alleged sexual assault undermines the relevance and materiality of Kim’s confidential records. And failure to consider that statement, if admissible, undermines the delicate balancing of defendants’ and victims’ rights established in Chambers, Justice Pierre-Louis explains. JUSTICES PATTERSON, WAINER APTER, NORIEGA, and HOFFMAN join in JUSTICE FASCIALE’s opinion. JUSTICE PIERRE-LOUIS filed a dissent, in which CHIEF JUSTICE RABNER joins. 4  SUPREME COURT OF NEW JERSEY A-5 September Term 2025 090566 State of New Jersey, Plaintiff-Respondent, v. R.F.P., Defendant-Appellant. ________________________________________________________________ K.S., Intervenor-Respondent. On appeal from the Superior Court, Appellate Division. Argued Decided March 2, 2026 July 9, 2026 Alyssa Aiello, Assistant Deputy Public Defender, argued the cause for appellant (Jennifer N. Sellitti, Public Defender, attorney; Alyssa Aiello, of counsel and on the briefs). Deepa S. Y. Jacobs, Assistant Prosecutor, argued the cause for respondent (Mark Musella, Bergen County Prosecutor, attorney; Deepa S. Y. Jacobs, of counsel and on the briefs). Richard D. Pompelio argued the cause for intervenor K.S. (New Jersey Crime Victims’ Law Center, attorneys; 1  Dyanne Veloz Lluch, of counsel and on the brief, and Richard D. Pompelio, on the brief). Angela E. Juneau argued the cause for amicus curiae Association of Criminal Defense Lawyers of New Jersey (Pashman Stein Walder Hayden, attorneys; C.J. Griffin, of counsel, and Angela E. Juneau, of counsel and on the brief). Ronald K. Chen argued the cause for amicus curiae American Civil Liberties Union of New Jersey (Rutgers Constitutional Rights Clinic Center for Law & Justice, and American Civil Liberties Union of New Jersey Foundation, attorneys; Jeanne LoCicero and Ezra D. Rosenberg, of counsel and on the brief, and Ronald K. Chen and Jessica Rofé, on the briefs). Kaili E. Matthews, Deputy Attorney General, argued the cause for amicus curiae Attorney General of New Jersey (Jennifer Davenport, Attorney General, attorney; Kaili E. Matthews, of counsel and on the brief). JUSTICE FASCIALE delivered the opinion of the Court. In State v. Chambers, we set forth a standard to balance two important sets of rights: a defendant’s constitutional right to present a meaningful defense, and the significant privacy interests of sexual assault victims. 252 N.J. 561, 589-91 (2023). Under that careful balance, a defendant may obtain an in camera inspection of a victim’s pre-incident mental health records only upon showing, by a preponderance of the evidence, “(1) that there is a substantial, particularized need for such access; (2) that the information sought 2 is relevant and material; and (3) that the information is not available through less intrusive means.” Ibid. In this appeal, we consider whether the trial judge abused his discretion by granting defendant’s motion for an in camera review of the alleged sexual assault victim’s pre-incident mental health records. We conclude the trial judge correctly applied Chambers, and, upon review of the record, we discern no abuse of discretion in his finding that defendant made a sufficient showing for the trial judge to conduct a limited and narrow in camera review. We therefore reverse the judgment of the Appellate Division. I. In April 2021, Kim, the alleged victim, age eighteen, moved to live with her biological father, Andrew. 1 Andrew resided with his brother (defendant); his sister, Tamara; and her boyfriend, Scott. On May 30, 2021, Kim told Andrew that defendant sexually assaulted her the day before. Kim and Andrew went to the hospital, where Kim was examined by a sexual assault nurse and interviewed by detectives from the Bergen County Prosecutor’s Office. Kim told the detectives that while she was in defendant’s room searching for her cat, defendant kissed her, pushed her onto his bed, and then proceeded 1 We use pseudonyms for the alleged victim and her family members. 3 to engage in further sexual acts without her consent. Kim self-reported her medical history as “[a]utism, bipolar I, PTSD, asthma, seizures, hypothyroid, [and] anxiety,” and that her current medications included “[V]istaril, [S]eroquel, trazadone, lithium, desmopressin, albuterol, Lamictal, [S]ynthroid, clindamycin, benzoyl peroxide, [and] ‘intonis.’” Kim also shared with the detectives that after the incident, she texted her best friend and former boyfriend, Ivan. In their text messages, Kim stated, “There is something [defendant] did in this house . . . I don’t know who to tell . . . nobody will believe me.” Ivan then asked if “it was sexual”; Kim responded “yes.” Ivan further inquired whether defendant “raped someone,” and Kim replied, “He did it to me and told me that I can’t tell anyone.” Kim said multiple times her father “won’t believe me.” The following day, Kim informed the police -- in a sworn statement -- that she had previously reported to her father that she had been raped on “countless occasions.” Contrary to her statements to Ivan, Kim told officers that her father always took her reports of rape seriously. Defendant, during his lengthy statement to the police, explained that after Kim went into his bedroom to look for her cat, she got into his bed to “cuddle,” and while they cuddled, their touching became sexual and “one thing 4 led to another.” He explained the sex was consensual, conceded it was “wrong,” and expressed shame and regret. 2 A grand jury indicted defendant and charged him with various offenses, including second-degree sexual assault and fourth-degree criminal sexual contact. According to the defense, Kim gave conflicting accounts regarding the details of the incident, most notably “on the point of ejaculation.” In her text 2 The State asserts that, at the conclusion of defendant’s statement to police, he “reluctantly conceded that [Kim] was uncomfortable” and “[u]ltimately . . . admitted . . . that he knew his actions were not consensual.” The defense, however, argues that this characterization misrepresents his statement. Specifically, defendant asserts that (1) he believed Kim was merely “uncomfortable in the position in which she was lying on the bed” and (2) the “purported admissions” were “semi-affirmative answers” given by defendant, a developmentally disabled person, after being “doggedly” questioned by police for over two hours. We disagree with our dissenting colleague that defendant’s statements to police are dispositive to a Chambers analysis. The parties dispute the substance of defendant’s statements, and defendant indicated his intent to challenge their trial admissibility. We cannot conclude, as the dissent contends, that defendant’s “own words” conclusively show that “Kim did not imagine or falsify what transpired during the alleged sexual assault.” Post at ___ (slip op. at 2). Defendants are presumed innocent until proven guilty and the weight of the prosecution’s evidence, including defendant’s own statements, is for the jury to resolve. Additionally, any purported admissions made by defendant do not eliminate his right to mount a meaningful defense. Under the totality of the facts of this case, which are in stark contrast to the facts in Chambers, his statements are not relevant to our analysis in determining whether defendant is entitled to a limited and narrow in camera review of the records. 5 exchange with Ivan, Kim stated defendant “came on me.” The next day, she reportedly told the sexual assault nurse examiner she was not sure if defendant ejaculated. In response to the police asking Kim if defendant ejaculated, Kim told them, “I wouldn’t have known what to look for.” Upon police follow-up questions, Kim responded “I don’t know, I don’t know.” After learning about Kim’s diagnoses and psychotropic medications, defense counsel retained an investigator to learn whether a connection exists between Kim’s self-reported mental illnesses and her ability to perceive, recall, or recount details of the incident or might reflect a proclivity to imagine or fabricate. In February 2022, the investigator interviewed Tamara and Scott, and in March 2023, he interviewed Ivan and Peggy, Kim’s adoptive mother. Tamara had also been interviewed by a different investigator in 2021, just a few weeks after the incident occurred. The record contains the investigators’ summaries of the interviews. In her 2021 interview, Tamara explained that Kim’s biological mother died when Kim was three years old and that Andrew lost custody of Kim due to his own disabilities. Tamara stated that in April (a month or two before the incident), Andrew helped Kim check herself out of Virtua Memorial Hospital, where Kim had been receiving treatment for mental health illnesses. According to Tamara, Kim left the hospital without her adoptive parents’ 6 knowledge. Tamara reported that Kim bragged about accusing an ex- boyfriend of rape when he broke up with her, and that she planned to make it seem like her boyfriend raped her because she did not get what she wanted. Tamara also told investigators that Kim had a habit of making false accusations when upset and had an inability to appreciate the consequences of lying due to her mental incapacities. Scott told the investigator that Kim had been in a psychiatric hospital before she moved into the house where the incident occurred. Scott corroborated Tamara’s statement that Kim was not supposed to be released from the hospital and that Andrew checked her out of that hospital without her adoptive parents’ knowledge. Scott explained that he too had heard Kim brag about making false accusations of rape against various men. And that when he asked Kim why she would do that, Kim stated, “[T]hat’s how I am.” Peggy informed investigators that she and her husband adopted Kim at four years old, and she described Kim as someone with “many learning disabilities and challenges.” Peggy reported that Kim had an extensive history of psychiatric treatment, including a ten-month stay in a residential group home. She confirmed that, prior to moving into the house with her biological father, Kim left the program at Virtua Memorial Hospital against clinical advice. Stating that she was uncomfortable talking about the incident, Peggy 7 explained that Kim is “troubled and it is hard to believe what she says sometimes.” Ivan corroborated Peggy’s description of Kim. He said that Kim had several mental health conditions, including autism and PTSD, and that Kim had been prescribed medication. Ivan did not believe Kim took her medication and described her, like the others who were interviewed, as someone who “tends to lie a lot.” Ivan said he was her best friend at the time of the incident and the first person she contacted. 3 Defendant filed a motion for an in camera inspection of Kim’s pre- incident mental health records. Following the standard we outlined in Chambers, 252 N.J. at 589-91, he argued that (1) there is a “substantial, particularized need” for such inspection because Kim’s mental illnesses were connected to her ability to “perceive, recall, or recount the events of the alleged assault, or a proclivity to imagine or fabricate them”; (2) the mental health “information sought is relevant and material” to whether defendant reasonably believed that Kim consented to the sexual acts; and (3) the “information [sought] is not available through less intrusive means.” Defendant also supplied the trial judge with medical articles addressing bipolar 3 Ivan also underwent a sworn audio interview with the State in which he explained that Kim contacted him over Facebook Messenger after the assault. 8 disorder and PTSD. The articles explained that those conditions can produce testimonial incapacities, specifically false memories and an inability to accurately recall or recount events. 4 The State provided the trial judge articles as well, focused on autism and the ability and tendency to lie. 5 The trial judge conducted oral argument and rendered a comprehensive oral opinion. In exercising his discretion to order an in camera inspection, the judge considered: Kim’s mental illnesses; the list of multiple medications she had been prescribed at the time of the incident, including an antipsychotic, Seroquel; Kim’s statements to the police, including that she had reported rape on “countless occasions”; Kim’s statement to the sexual assault nurse examiner; defendant’s statements; the statements from Tamara, Scott, Ivan, and Peggy, which corroborated that Kim had a history of making false accusations of rape and not being truthful; evidence that Kim left Virtua 4 Defendant presented the following articles: Andrea Pozza et al., Post- Traumatic Stress Disorder Secondary to Manic Episodes with Hypersexuality in Bipolar Disorder: A Case Study of Forensic Psychotherapy, 17 Clinical Neuropsychiatry 181 (2020); Henry Otgaar et al., What Drives False Memories in Psychopathology? A Case for Associative Activation, 5 Clinical Psych. Sci. 1048 (2017); Brandon May, Is There a Link Between Bipolar Disorder and Lying?, Med. News Today (May 25, 2023). 5 The State presented the following articles: Pier Jaarsma et al., Living the Categorical Imperative: Autistic Perspectives on Lying and Truth Telling Between Kant and Care Ethics, 15 Med. Health Care & Phil. 271 (2011); Annie S. Li et al., Exploring the Ability to Deceive in Children With Autism Spectrum Disorders, 41 J. Autism Dev. Disorder 185 (2011). 9 Memorial Hospital against clinical advice close in time to the incident; Ivan’s statement that he believed Kim was not taking her medicine; and the medical articles. In his oral decision, the trial judge stated: The discovery provided by the State and the interviews conducted by the Defense investigator with [Kim]’s family members and friends do demonstrate that she has had multiple mental health diagnoses and developmental disabilities that have required multiple hospitalizations. Also, the substance of the interviews with various family and friends of [Kim], although ultimately that may be left to a question for the jury to consider whether or not [Kim]’s accusations are credible, these interviews with family and friends also are consistent with another with respect to a tendency or a knowledge that these witnesses have of [Kim]’s . . . alleged tendency . . . to lie or to fabricate, including about the very substance of the allegations that she has made against [defendant]. This evidence of pre-incident mental illness establishes certainly, and this Court agrees, by a preponderance of the evidence that there is a substantial particularized need for [Kim]’s pre-incident mental health records. The information sought from these records most certainly is relevant and material to this case as it may indicate that [Kim] may have a proclivity to imagine or fabricate the alleged sexual assault as well as have a bearing on her ability to perceive, recall or recollect, and most certainly this information is not available through any less intrusive means. So, this Court agrees while not agreeing fully that any of these records should just be released to the Defense, most certainly the Defense has met its burden for the 10  Court to conduct an in camera review of [Kim]’s pre- incident mental health records. Accordingly, the trial judge ordered that Kim’s pre-incident mental health treatment records limited to Virtua Memorial Hospital and Bergen Regional Medical Center -- her two most recent hospitalizations -- be produced to the trial judge for an in camera review. He explicitly stated that the production of mental health records for in camera review does not mean that those records will automatically be disclosed to defendant following such review. The State and the New Jersey Crime Victims’ Law Center (NJCVLC), on behalf of Kim, filed motions for reconsideration. The trial judge denied the motions and stated in part: I still find we have far more than just bald assertions substantiating or meeting the prongs under Chambers. There’s certainly substantial particularized need for access to the records because . . . they certainly relate and connect the mental illness of the victim and her ability -- or inability to perceive, recall, or recount the events of the alleged assault perpetrated on her or . . . a proclivity to imagine or fabricate them. So -- and the burden is by a preponderance of the evidence and I’m basing my decision, at least for the in camera review, on a totality of what’s before this Court. And certainly, that prong of Chambers has been shown. It’s not just simply because there is a diagnosis of the alleged victim of autism, bipolar I disorder, post- traumatic stress disorder, anxiety, and a variety of medications that she’s prescribed, as well as the history both preceding and subsequent to the alleged sexual assault. So, certainly, that prong of Chambers was met. 11  Certainly, the records are relevant and material to the alleged victim’s ability to perceive, recall, or recount the alleged assault or . . . proclivity to imagine or fabricate it. Again, it’s a totality of what’s before the Court. These are more than mere bald assertions, given the history of mental illness . . . which is undisputed by the State, as well as the investigation conducted by the defendant. And it’s not lost on me the argument from the State that certain witnesses may have a bias or a reason to lie or fabricate here. But that goes both ways. It’s one or the other purposes of conducting an in camera review. It certainly might be a preview of both parties’ cases should the matter go to trial. But the records are certainly relevant and material. And certainly, the information in these records is not available through less intrusive means. .... So, for all the reasons that the Court stated in its initial decision -- initial lengthy oral decision, I am denying the motion for reconsideration by the State, as well as denying the motion independently filed on behalf of [Kim]. [(emphases added).] The trial judge emphasized that his decision addressed only the first Chambers stage: I just want to make it clear that just because . . . I’m addressing the threshold issues of the prongs of Chambers, it’s not any indication as to whether or not I believe or I found that there is any actual evidence of this. You know, the question is, was that -- was that threshold met under Chambers for the release of the records, at least for an in camera review at this point. 12  Ultimately, whether or not they’re going to be released to counsel, that’s a separate issue. The Appellate Division granted the State and Kim’s motions for leave to appeal. The appellate court determined that defendant failed to meet the heightened discovery standard we established in Chambers. It concluded that the trial judge erred by failing to address issues of veracity, reliability, and bias raised by the individual interviews, and therefore abused his discretion by ordering an in camera inspection. Accordingly, the Appellate Division reversed the orders permitting the limited in camera review of Kim’s pre- incident mental health records from her two most recent hospitalizations. We granted defendant’s motion for leave to appeal. 261 N.J. 568 (2025). We also granted NJCVLC’s motion to file an intervenor brief on behalf of Kim, as well as motions on behalf of the Attorney General, the American Civil Liberties Union (ACLU), and the Association of Criminal Defense Lawyers of New Jersey (ACDL) to appear as amici curiae. II. Defendant argues that the trial judge did not abuse his discretion by ordering the limited and narrow in camera inspection of Kim’s pre-incident mental health records. As to the connection between Kim’s mental illnesses and her ability to “perceive, recall, or recount the events of the incident” or “imagine or fabricate them,” defendant explains that he relies on more than 13 Kim’s mental illnesses and prescriptions for psychotropic medications. Specifically, defendant relies on: the fact that weeks before the incident, Kim received mental health treatment at Virtua Memorial Hospital but left against clinical advice; Ivan’s statement that he did not believe Kim took her medication; Tamara, Scott, Peggy, and Ivan’s statements that Kim had a history of making false statements, including false rape accusations; and medical articles that addressed a link between Kim’s mental illnesses, bipolar disorder and PTSD, and testimonial incapacities, specifically false memories and an inability to accurately recall or recount events. Altogether, defendant contends that those pieces of evidence satisfy the preliminary showing required to grant an in camera review of the records. The State recognizes a defendant’s right to a meaningful defense and to secure, where appropriate, an in camera inspection of a victim’s mental health records. But it asserts that a motion seeking such an inspection requires affidavits, certifications, or testimony. The State maintains that defendant failed to meet the standard we articulated in Chambers. The NJCVLC, on behalf of Kim, and the Attorney General join the State’s arguments. The NJCVLC stresses that because defendant failed to establish the requirements of the preliminary Chambers step, the trial judge’s decision was an unwarranted intrusion into Kim’s right of privacy. 14  The ACLU argues that the trial judge complied with Chambers and did not abuse his discretion by preliminarily ordering an in camera inspection. It contends that the trial judge made specific findings of fact and rational inferences based on the totality of the record before him and that the Appellate Division improperly substituted its own factual weighing for that of the trial judge. The ACLU points to generally accepted reference sources that connect Kim’s diagnoses and medications with how experiences are processed, remembered, or recounted. 6 And it contends Kim exhibited disordered behaviors consistent with the cognitive impairments associated with her mental illnesses and medications. Thus, the ACLU emphasizes that defendant demonstrated some evidential showing that connects the alleged mental illness to the victim’s inability to perceive, recall, or recount the events of the alleged assault, or a proclivity to imagine or fabricate them. The ACDL argues that defendant produced more than sufficient evidence under the Chambers standard for a preliminary in camera inspection of pre-incident records. It contends that the Appellate Division overlooked the 6 The ACLU cites: Am. Psych. Ass’n, Diagnostic & Stat. Manual of Mental Disorders (DSM-5-TR) (5th ed. 2022); Kaplan & Sadock, Comprehensive Textbook of Psychiatry (11th ed. 2024); and Physicians’ Desk Reference (71st ed. 2017). The PDR is no longer issued as a physical book and has transitioned entirely to a digital format known as the Prescribers’ Digital Reference (PDR.net), which is continuously updated online. 15 peer-reviewed articles that connect Kim’s diagnoses with tendencies toward misperceiving events or falsifying facts; erred by focusing on credibility issues, even though the State did not dispute Kim’s medical conditions and medication use; and discounted the statements by Ivan, Tamara, Scott, and Peggy, which were consistent with each other and with Kim’s own testimony. III. An appellate court “generally defer[s] to a trial court’s disposition of discovery matters unless the court has abused its discretion or its determination is based on a mistaken understanding of the applicable law.” State v. Knight, 256 N.J. 404, 415 (2024) (quoting State v. Brown, 236 N.J. 497, 521 (2019)). “An abuse of discretion occurs by making decisions ‘without a rational explanation, [that] inexplicably depart[] from established policies, or [that] rest[] on an impermissible basis.’” Chambers, 252 N.J. at 594-95 (first and third alterations in original) (quoting Flagg v. Essex Cnty. Prosecutor, 171 N.J. 561, 571 (2002)). Reviewing courts, however, “need not defer . . . to a discovery order that is well ‘wide of the mark,’ or ‘based on a mistaken understanding of the applicable law.’” Knight, 256 N.J. at 416 (quoting State v. Hernandez, 225 N.J. 451, 461 (2016)). A trial court’s legal conclusions are reviewed de novo. State v. Bullock, 253 N.J. 512, 515 (2023). 16  IV. “[A] heightened discovery standard governs a defendant’s motion for pre-incident mental health records from a sexual assault victim.” Chambers, 252 N.J. at 571. The standard is rigorous due to the need to balance a criminal defendant’s constitutional right to “a meaningful opportunity to present a complete a defense,” State v. Budis, 125 N.J. 519, 531 (1991) (quoting Crane v. Kentucky, 476 U.S. 683, 690 (1986)), against the significant privacy interests of sexual assault victims, State v. D.R.H., 127 N.J. 249, 259 (1992). In Chambers, we held that “a defendant is entitled to present a meaningful defense by making a good-faith request for pre-incident mental health records of a sexual assault victim.” 252 N.J. at 589. To obtain such records, the defendant must satisfy a two-stage standard: first, the trial judge must make a preliminary gatekeeping determination as to whether there is sufficient justification to warrant an in camera review; and second, if the defendant meets “that heavy preliminary burden,” the judge will conduct a substantive in camera inspection to determine whether production to the defendant is warranted. Id. at 571. “If a defendant files a motion seeking access to pre-incident mental health records, a victim is entitled to notice by the county prosecutor’s office and must have an opportunity to be heard, with or without independent 17 counsel.” Id. at 589. Here, Kim did not initially receive notice of the motion. The record is unclear as to precisely when Kim was eventually notified; we discern that it was at some point before she joined the State’s motion for reconsideration. We take this opportunity to remind the State of its duty to provide timely notice to a victim whenever a defendant files a Chambers motion, and to remind trial judges of their obligation to ensure -- at the onset of the hearing -- that the victim has received both notice and an opportunity to oppose the motion, as required by the Crime Victims’ Bill of Rights, N.J.S.A. 52:4B-36(r). The first Chambers stage requires a defendant to show, by a preponderance of the evidence, that: (1) the defendant has “a substantial, particularized need” for the records; (2) “the information sought [therein] is relevant and material;” and (3) “the information is not available through less intrusive means.” Id. at 590. If a defendant satisfies that three-part discovery standard, then the defendant is entitled to have the trial judge conduct an in camera inspection. Id. at 591. During the second stage, the judge must determine whether to “pierce” the applicable mental health privilege, redact the records, and make them available under a protective order. Id. at 592. At issue here is the first stage: whether defendant is entitled to have the trial judge conduct an in camera inspection of the records. W