Jaffee v. Redmond

United States Supreme Court518 U.S. 1 (1996)

Facts

Mary Lu Redmond (defendant), a police officer, shot and killed Ricky Allen during a dangerous encounter while she was on duty. Jaffee, the administrator of Allen’s estate (plaintiff), brought a wrongful death suit against Redmond, claiming that she used excessive force in the killing. At trial, the administrator questioned Redmond about counseling sessions she had had with a licensed social worker after the shooting. Redmond refused to testify about the sessions despite the district court’s order to do so. The district judge instructed the jury that there was no legal justification for Redmond’s refusal to answer the questions and that the jury could assume that the sessions with the social worker contained information unfavorable to Redmond. As a result, the jury found in favor of the administrator. The United States Court of Appeals for the Seventh Circuit reversed, recognizing a federal psychotherapist-patient privilege. The United States Supreme Court granted certiorari.

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