Jaffee v. Redmond

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Jaffee v. Redmond

Supreme Court of the United States

Argued February 26, 1996
Decided June 18, 1996


Full case name:	Jaffee, special administrator for Ricky Allen, petitioners, v. Mary Lu Redmond and Village of Hoffman Estates, Illinois

Prior history:	Jury verdict for petitioners reversed by Seventh Circuit.

Holding

The Federal Rules of Evidence recognize a patient-doctor evidentiary privilege that extends to licensed social workers.

Court membership

Chief Justice: William Rehnquist
Associate Justices: John Paul Stevens, Sandra Day O'Connor, Antonin Scalia, Anthony Kennedy, David Souter, Clarence Thomas, Ruth Bader Ginsburg, Stephen Breyer

Case opinions

Majority by: Stevens
Joined by: O'Connor, Kennedy, Souter, Thomas, Ginsburg, Breyer
Dissent by: Scalia
Joined by: Rehnquist

Laws applied

Fed. R. Evid. 501

In Jaffee v. Redmond, 518 U.S. 1 (1996), the Supreme Court created a physician-patient privilege in the Federal Rules of Evidence.

1 Facts
2 Majority Opinion
3 Dissenting Opinion
4 External links

[edit] Facts

Mary Lu Redmond was a police officer for the Village of Hoffman Estates, Illinois. On June 27, 1991, she was the first to respond to a fight-in-progress call. She arrived to find Ricky Allen chasing another man and brandishing a butcher knife. Redmond repeatedly ordered Allen to drop the knife, but Allen ignored her. At one point in the chase, it appeared to Redmond that Allen was about to stab the man he was chasing, and so she shot Allen. Allen died at the scene.

Acting as the representative of Allen's estate, Jaffee filed suit under 42 U.S.C. § 1983, claiming that Redmond had used excessive force during the altercation. Witnesses testified that Allen was not armed during the altercation. During discovery, Jaffee discovered that Redmond had sought counseling from a licensed clinical social worker. Jaffee sought the social worker's notes for the purpose of cross-examining Redmond at the trial. Redmond opposed the request, claiming that the notes were protected by the psychotherapist-patient privilege. The trial judge rejected this argument, and the jury later awarded Allen's estate $545,000 in damages.

Jaffee appealed to the Seventh Circuit, which vacated the decision of the trial court and remanded. In its opinion, the privilege of which Redmond sought to avail herself did exist in federal law, and the trial court should have applied it. Jaffee asked the Supreme Court to review the Seventh Circuit's decision, and it agreed to do so.

[edit] Majority Opinion

Justices John Paul Stevens, Sandra Day O'Connor, Anthony Kennedy, David Souter, Clarence Thomas, Ruth Bader Ginsburg, and Stephen Breyer joined the majority opinion, ruling that the patient-psychotherapist privilege should be respected, except when the patient's privacy is outweighed by the evidentiary need for disclosure. Antonin Scalia and Chief Justice Rehnquist joined the dissenting opinion.