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14 Pennsylvania opinions name it 7 courts 1986–2019 0 in the last five years
The cases below were cited by Pennsylvania courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Rost v. State Board of Psychologygreen2 sentences2003See Commonwealth v. Davis, 543 Pa. 628, 632 , 674 A.2d 214 , 216 (1996) (statutory sexual assault counselor privilege waived where the victim provides the prosecution access to the records); Joe v. Prison Health Services Inc. 782 A.2d 24, 31 (Pa. Commw. 2001) (once attorney-client communications have been disclosed to a third party, the privilege is deemed waived); Rost v. State Board of Psychology, 659 A.2d 626, 629 (Pa. Commw. 1995) (Psychologist-client privilege may be waived where client has made information known to third persons). 2000Rost v. State Board of Psychology, 659 A.2d 626 (Pa. Commw. 1995), appeal denied, 543 Pa. 699 , 670 A.2d 145 (1995). | 2 | 3 |
Matter of Adoption of Embickgreen2 sentences1991In Matter of Adoption of Embick, 351 Pa.Super. 491 , 506 A.2d 455 (1986), another panel of this court also discussed the public policy supporting confidential communications to psychotherapists: There can be no doubt that the purpose of the psychologist-client privilege is to encourage people to seek professional help for their mental or emotional problems, and that purpose is best accomplished when people in need of the psychotherapeutic treatment know that what they tell their therapist during treatment will not be disclosed to anyone. 1991In Matter of Adoption of Embick, 351 Pa.Super. 491 , 506 A.2d 455 (1986), another panel of this court also discussed the public policy supporting confidential communications to psychotherapists: There can be no doubt that the purpose of the psychologist-client privilege is to encourage people to seek professional help for their mental or emotional problems, and that purpose is best accomplished when people in need of the psychotherapeutic treatment know that what they tell their therapist during treatment will not be disclosed to anyone. | 2 | 3 |
In the Interest of Bendergreen2 sentences2000See In Interest of Bender, 366 Pa.Super. 450 , 531 A.2d 504, 505 (1987); In re Adoption of Embick, 351 Pa.Super. 491 , 506 A.2d 455, 460 (1986). 2000See In Interest of Bender, 366 Pa.Super. 450 , 531 A.2d 504, 505 (1987); In re Adoption of Embick, 351 Pa.Super. 491 , 506 A.2d 455, 460 (1986). | 2 | 2 |
Commonwealth v. Goldblumgreen2 sentences1991In Commonwealth v. Goldblum, 498 Pa. 455, 464 , 447 A.2d 234, 239 (1982), our Supreme Court said: ‘Between an attorney and client, the privilege is confined to confidential communications. . ..’ “There can be no doubt that the purpose of the psychologist-client privilege is to encourage people to seek professional help for their mental or emotional problems, and that purpose is best accomplished when people in need of psychotherapeutic treatment know that what they tell their therapist during treatment will not be disclosed to anyone. ££[T]he analysis suggested by Dean Wigmore would compel the 1991In Commonwealth v. Goldblum, 498 Pa. 455, 464 , 447 A.2d 234, 239 (1982), our Supreme Court said: ‘Between an attorney and client, the privilege is confined to confidential communications. . ..’ “There can be no doubt that the purpose of the psychologist-client privilege is to encourage people to seek professional help for their mental or emotional problems, and that purpose is best accomplished when people in need of psychotherapeutic treatment know that what they tell their therapist during treatment will not be disclosed to anyone. ££[T]he analysis suggested by Dean Wigmore would compel the | 1 | 2 |
In re Kuma K-9 Security, Inc.green1 sentence2011See Matter of Adoption of Embick, 506 A.2d 445, 461 (Pa. Super. 1986) (upholding a lower court’s decision to permit a psychologist to testify despite the psychologist-client privilege statute). 2 With regards to a client’s identity, it cannot be said that confidentiality of a client’s name, and only his name, is “essential to the full and satisfactory maintenance of’ the attorney-client relationship. | 1 | 1 |
Commonwealth v. Davisgreen2 sentences2003See Commonwealth v. Davis, 543 Pa. 628, 632 , 674 A.2d 214 , 216 (1996) (statutory sexual assault counselor privilege waived where the victim provides the prosecution access to the records); Joe v. Prison Health Services Inc. 782 A.2d 24, 31 (Pa. Commw. 2001) (once attorney-client communications have been disclosed to a third party, the privilege is deemed waived); Rost v. State Board of Psychology, 659 A.2d 626, 629 (Pa. Commw. 1995) (Psychologist-client privilege may be waived where client has made information known to third persons). 2003See Commonwealth v. Davis, 543 Pa. 628, 632 , 674 A.2d 214 , 216 (1996) (statutory sexual assault counselor privilege waived where the victim provides the prosecution access to the records); Joe v. Prison Health Services Inc. 782 A.2d 24, 31 (Pa. Commw. 2001) (once attorney-client communications have been disclosed to a third party, the privilege is deemed waived); Rost v. State Board of Psychology, 659 A.2d 626, 629 (Pa. Commw. 1995) (Psychologist-client privilege may be waived where client has made information known to third persons). | 1 | 1 |
Joe v. Prison Health Services, Inc.green1 sentence2003See Commonwealth v. Davis, 543 Pa. 628, 632 , 674 A.2d 214 , 216 (1996) (statutory sexual assault counselor privilege waived where the victim provides the prosecution access to the records); Joe v. Prison Health Services Inc. 782 A.2d 24, 31 (Pa. Commw. 2001) (once attorney-client communications have been disclosed to a third party, the privilege is deemed waived); Rost v. State Board of Psychology, 659 A.2d 626, 629 (Pa. Commw. 1995) (Psychologist-client privilege may be waived where client has made information known to third persons). | 1 | 1 |
Commonwealth v. Simsgreen2 sentences1987See Commonwealth v. Sims, 513 Pa. 366, 373 , 521 A.2d 391, 395 (1987) (sixth amendment right of confrontation did not abrogate attorney-client privilege); citing Washington v. Texas, 388 U.S. 14 , 87 S.Ct. 1920 , 18 L.Ed.2d 1019 (1967); Commonwealth v. Allen, 501 Pa. 525 , 462 A.2d 624 (1983) (same). 1987See Commonwealth v. Sims, 513 Pa. 366, 373 , 521 A.2d 391, 395 (1987) (sixth amendment right of confrontation did not abrogate attorney-client privilege); citing Washington v. Texas, 388 U.S. 14 , 87 S.Ct. 1920 , 18 L.Ed.2d 1019 (1967); Commonwealth v. Allen, 501 Pa. 525 , 462 A.2d 624 (1983) (same). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Commonwealth v. Kyle
green
2 sentences2018In Kyle , the Superior Court distinguished Ritchie because, unlike the statute at issue in that case, the Pennsylvania statute synthesizing the psychologist-client privilege "was an absolute privilege" that "made no exceptions for disclosure." 533 A.2d at 130 . 1992Murphy, denied defense counsel’s request and held that pursuant to our decision in Commonwealth v. Kyle, 367 Pa.Super. 484 , 533 A.2d 120 (1987), the psychologist-client privilege was absolute, thereby prohibiting review of the psychotherapist’s records by the trial court itself. | 2 | 1992–2018 |
Commonwealth v. Harris
green
1 sentence2019Harris, 32 A.3d at 592-93 . | 1 | 2019–2019 |
Commonwealth v. Berger
green
1 sentence2018In Berger , the Superior Court stressed the same distinction in a case where, given the record before it, the court could not "discern the extent to which disclosure is permissible or required" under the statutes governing confidential communications to sexual assault counselors and psychotherapists. 96 A.3d at 1052 . | 1 | 2018–2018 |
Kalenevitch v. Finger
green
1 sentence1995Kalenevitch v. Finger, 407 Pa.Superior Ct. 431, 595 A.2d 1224 (1991). | 1 | 1995–1995 |
Commonwealth v. Allen
green
2 sentences1987See Commonwealth v. Sims, 513 Pa. 366, 373 , 521 A.2d 391, 395 (1987) (sixth amendment right of confrontation did not abrogate attorney-client privilege); citing Washington v. Texas, 388 U.S. 14 , 87 S.Ct. 1920 , 18 L.Ed.2d 1019 (1967); Commonwealth v. Allen, 501 Pa. 525 , 462 A.2d 624 (1983) (same). 1987See Commonwealth v. Sims, 513 Pa. 366, 373 , 521 A.2d 391, 395 (1987) (sixth amendment right of confrontation did not abrogate attorney-client privilege); citing Washington v. Texas, 388 U.S. 14 , 87 S.Ct. 1920 , 18 L.Ed.2d 1019 (1967); Commonwealth v. Allen, 501 Pa. 525 , 462 A.2d 624 (1983) (same). | 1 | 1987–1987 |
Washington v. Texas
green
2 sentences1987See Commonwealth v. Sims, 513 Pa. 366, 373 , 521 A.2d 391, 395 (1987) (sixth amendment right of confrontation did not abrogate attorney-client privilege); citing Washington v. Texas, 388 U.S. 14 , 87 S.Ct. 1920 , 18 L.Ed.2d 1019 (1967); Commonwealth v. Allen, 501 Pa. 525 , 462 A.2d 624 (1983) (same). 1987See Commonwealth v. Sims, 513 Pa. 366, 373 , 521 A.2d 391, 395 (1987) (sixth amendment right of confrontation did not abrogate attorney-client privilege); citing Washington v. Texas, 388 U.S. 14 , 87 S.Ct. 1920 , 18 L.Ed.2d 1019 (1967); Commonwealth v. Allen, 501 Pa. 525 , 462 A.2d 624 (1983) (same). | 1 | 1987–1987 |
Commonwealth v. Garcia
green
1 sentence1986Commonwealth v. Goldblum, 498 Pa. 455 , 447 A.2d 234 (1982), Commonwealth v. Garcia, 478 Pa. 406 , 387 A.2d 406 (1978), and Commonwealth v. Petrino, 332 Pa.Super. 13 , 480 A.2d 1160 (1984), cert. denied, — U.S. —, 105 U.S. 2149 , 85 L.Ed.2d 505 , were all cases wherein testimony was sought to be excluded on the basis of the psychologist-client privilege. 42 Pa.C.S. § 5944. | 1 | 1986–1986 |
Commonwealth v. Petrino
green
2 sentences1986Commonwealth v. Goldblum, 498 Pa. 455 , 447 A.2d 234 (1982), Commonwealth v. Garcia, 478 Pa. 406 , 387 A.2d 406 (1978), and Commonwealth v. Petrino, 332 Pa.Super. 13 , 480 A.2d 1160 (1984), cert. denied, — U.S. —, 105 U.S. 2149 , 85 L.Ed.2d 505 , were all cases wherein testimony was sought to be excluded on the basis of the psychologist-client privilege. 42 Pa.C.S. § 5944. 1986Commonwealth v. Goldblum, 498 Pa. 455 , 447 A.2d 234 (1982), Commonwealth v. Garcia, 478 Pa. 406 , 387 A.2d 406 (1978), and Commonwealth v. Petrino, 332 Pa.Super. 13 , 480 A.2d 1160 (1984), cert. denied, — U.S. —, 105 U.S. 2149 , 85 L.Ed.2d 505 , were all cases wherein testimony was sought to be excluded on the basis of the psychologist-client privilege. 42 Pa.C.S. § 5944. | 1 | 1986–1986 |
Petrino v. Pennsylvania
green
1 sentence1986Commonwealth v. Goldblum, 498 Pa. 455 , 447 A.2d 234 (1982), Commonwealth v. Garcia, 478 Pa. 406 , 387 A.2d 406 (1978), and Commonwealth v. Petrino, 332 Pa.Super. 13 , 480 A.2d 1160 (1984), cert. denied, — U.S. —, 105 U.S. 2149 , 85 L.Ed.2d 505 , were all cases wherein testimony was sought to be excluded on the basis of the psychologist-client privilege. 42 Pa.C.S. § 5944. | 1 | 1986–1986 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.