Jaffee v. Redmond Case Brief

Why is the case important?

The administrator of decedent Ricky Allen’s (“Mr. Allen”) estate filed suit alleging Mr. Allen’s constitutional rights were violated when he was killed by the Respondent, Redmond (the “Respondent”), an on-duty police officer.

Facts of the case

Mary Lu Redmond, a former police officer, received extensive counseling from a licensed clinical social worker after she shot and killed Ricky Allen. Carrie Jaffee, special administrator for Allen, filed suit in federal District Court alleging that Redmond had violated Allen’s constitutional rights by using excessive force in the encounter. During the trial, Jaffee sought access to the notes from Redmond’s counseling. Redmond’s counsel resisted asserting the conversations were protected against involuntary disclosure by a psychotherapist-patient privilege. The District Court judge rejected the argument, but the notes were not released. The judge instructed the jury that they could presume that the contents could have been unfavorable to Redmond. The jury awarded monetary damages. The Court of Appeals reversed the decision. It found that Federal Rule of Evidence 501 prompted the recognition of a psychotherapist-patient privilege.

Question

Is it appropriate for federal courts to recognize a psychotherapist privilege under F.R.E. Rule 501?
If the federal courts recognize a psychotherapist privilege, should the privilege extend to confidential communications made to licensed social workers in the course of psychotherapy?

Answer

Justice John Paul Stevens (J. Stevens) delivered the opinion for the United States Supreme Court (Supreme Court) in holding that the federal courts should recognize a psychotherapist privilege.
Further, the privilege should extend to confidential communications made by licensed social workers in the course of psychotherapy.

Conclusion

“The conversations between Officer Redmond and Karen Beyer and the notes taken during their counseling sessions are protected from compelled disclosure under Rule 501 of the Federal Rules of Evidence. The purpose of the attorney-client privilege is to “”encourage full and frank communication between attorneys and their clients and thereby promote broader public interests in the observance of law and administration of justice. The Court, however,  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.”

  • Case Brief: 1996
  • Petitioner: Jaffee
  • Respondent: Redmond
  • Decided by: Rehnquist Court

Citation: 518 US 1 (1996)
Argued: Feb 26, 1996
Decided: Jun 13, 1996