Wednesday, December 18, 2013

Jaffee v. Redmond case brief

Jaffee v. Redmond case brief summary
518 U.S. 1 (1996)


CASE SYNOPSIS
The Court granted writ of certiorari from the United States Court of Appeals for the Seventh Circuit, which had concluded that a psychotherapist-patient privilege existed in petitioner's action alleging respondent had violated deceased's constitutional rights under 42 U.S.C.S. § 1983 and for wrongful death under 740 Ill. Comp. Stat. § 180/1 et seq. (1994).

CASE FACTS
Petitioner was administrator of decedent's estate and respondent here was a former police officer. Respondent shot petitioner's deceased during the course of duty. As a result, petitioner brought suit alleging respondent had violated deceased's constitutional rights under42 U.S.C.S. § 1983 and for wrongful death under 740 Ill. Comp. Stat. § 180/1 et seq. (1994). During the course of discovery, petitioner requested notes obtained during respondent's psychotherapist sessions. Respondents refused to disclose the notes.

PROCEDURAL HISTORY
The trial court advised the jury that there was no legal justification for respondents' failure to respond and that the jury could therefore presume that the contents of the notes would have been unfavorable to respondents. The appellate court reversed and remanded.

DISCUSSION

  • The Supreme Court accepted the question of whether it was appropriate for federal courts to recognize a "psychotherapist privilege" under Fed. R. Evid. 501 on certiorari. 
  • The Court affirmed the existence of a psychotherapist-patient privilege, but rejected the balancing component of the privilege because doing so would eviscerate the effectiveness of the privilege.
CONCLUSION
Order upholding psychotherapist-patient privilege was affirmed, but Court rejected the balancing component of the privilege, which would make the promise of confidentiality contingent upon the trial judge's later evaluation of the relative importance of the patient's interest in privacy and the evidentiary need for disclosure, because doing so would eviscerate the effectiveness of the privilege.


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