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6 New York opinions name it 3 courts 1993–2025 3 in the last five years
The cases below were cited by New York 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 |
|---|---|---|
Farrow v. Allengreen2 sentences2025It is well settled that " ... once a patient puts the information into the hands of a third party who is completely unconnected to his or her treatment and who is not subject to any privilege, it can no longer be considered a confidence and the privilege must be deemed to have been waived as to that information." Farrow v. Allen, 194 A.D.2d 40, 44 (1993). 2024In most instances, "once a patient puts the information into the hands of a third party who is completely unconnected to his or her treatment and who is not subject to any privilege, it can no longer be considered a confidence and the privilege must be deemed to have been waived as to that information" (Farrow v Allen, 194 AD2d 40, 44 [1st Dept 1993]; see also People v Pagan, 190 Misc 2d 474 at 475-476 [Sup Ct, Kings County 2002]). | 4 | 5 |
People v. Pagangreen1 sentence2024In most instances, "once a patient puts the information into the hands of a third party who is completely unconnected to his or her treatment and who is not subject to any privilege, it can no longer be considered a confidence and the privilege must be deemed to have been waived as to that information" (Farrow v Allen, 194 AD2d 40, 44 [1st Dept 1993]; see also People v Pagan, 190 Misc 2d 474 at 475-476 [Sup Ct, Kings County 2002]). | 1 | 1 |
Bierenbaum v. New Yorkgreen1 sentence2022It follows therefore that, even if the information was intended to remain confidential when it was communicated, once a patient puts the information into the hands of a third party who is completely unconnected to his or her treatment and who is not subject to any privilege, it can no longer be considered a confidence and the privilege must be deemed to have been waived as to that information" ( Matter of Farrow v Allen , 194 AD2d 40, 44 [1st Dept 1993]; see People v Bierenbaum , 301 AD2d 119, 141-142 [1st Dept 2002], lv denied 99 NY2d 626 [2003], cert denied 540 US 821 [2003]). | 1 | 1 |
People v. Bierenbaumgreen1 sentence2022It follows therefore that, even if the information was intended to remain confidential when it was communicated, once a patient puts the information into the hands of a third party who is completely unconnected to his or her treatment and who is not subject to any privilege, it can no longer be considered a confidence and the privilege must be deemed to have been waived as to that information" ( Matter of Farrow v Allen , 194 AD2d 40, 44 [1st Dept 1993]; see People v Bierenbaum , 301 AD2d 119, 141-142 [1st Dept 2002], lv denied 99 NY2d 626 [2003], cert denied 540 US 821 [2003]). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in New York. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Friel v. Papa
green
1 sentence2024The Diocese argues that in the Second Department there is an exception to the waiver of privilege when an employer obtains records regarding psychological and spiritual counseling (see Friel v. Papa, 87 A.D.3d 1108 , 1109-1111 ). | 1 | 2024–2024 |
People v. Narducci
neutral
1 sentence2022Consequently, in the matter on appeal, by disclosing the details of his mental health condition to the criminal court for his own benefit, "[d]efendant waived the physician-patient privilege by disclosing records of this treatment to government employees who were not involved in treating defendant" ( People v Narducci , 177 AD3d 511 , 513 [1st Dept 2019], lv denied 34 NY3d 1080 [2019]). | 1 | 2022–2022 |
People v. Figueroa
green
1 sentence1993It follows therefore that, even if the information was intended to remain confidential when it was communicated, once a patient puts the information into the hands of a third party who is completely unconnected to his or her treatment and who is not subject to any privilege, it can no longer be considered a confidence and the privilege must be deemed to have been waived as to that information (see, People v Figueroa, 173 AD2d 156, 159 ; People v Hawkrigg, 138 Misc 2d 764, 765-766 ; see also, In re Von Bulow, 828 F2d 94, 103). | 1 | 1993–1993 |
People v. Hawkrigg
neutral
1 sentence1993It follows therefore that, even if the information was intended to remain confidential when it was communicated, once a patient puts the information into the hands of a third party who is completely unconnected to his or her treatment and who is not subject to any privilege, it can no longer be considered a confidence and the privilege must be deemed to have been waived as to that information (see, People v Figueroa, 173 AD2d 156, 159 ; People v Hawkrigg, 138 Misc 2d 764, 765-766 ; see also, In re Von Bulow, 828 F2d 94, 103). | 1 | 1993–1993 |
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.