People v. Gonzales

Case No.	Op. Below	Argument	Opinion	Vote	Author	Term
S191240	6th App.	02/06/13	03/18/13	7-0	Cantil-Sakauye	2013

Issue: whether the trial court properly applied the psychotherapist-patient privilege with regard to statements made by a parolee to his therapist during parole-mandated therapy sessions, and, if not, whether the trial court's error constitutes a violation of a federal constitutional right of privacy as well as a violation of the state statutory privilege

Holding: The court agreed with the Court of Appeal's conclusion that the trial court erred in permitting disclosure of defendant's psychological records and in admitting his former therapist's testimony in reliance upon the dangerous patient exception to the psychotherapist-patient privilege. However, the court disagreed with the Court of Appeal's determination that the trial court error constitutes an error of federal constitutional dimension.