California Court of Appeal

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In re M.L., E054939

In juvenile court's jurisdictional and dispositional hearing regarding two minor children, juvenile court's judgment ordering the release of all the children's mother's previously existing psychiatric records to the County Children and Family Services is reversed and remanded where: 1) to the extent the court disclosed and ordered the privileged documents admissible at trial, it erred without first conducting an in camera hearing to determine the issue first; 2) the psychiatric records were neither disclosable nor admissible at trial pursuant to section 5328; and 3) the mother did not tender her mental health status as an issue such that she waived the confidentiality of her privileged psychotherapist-patient records.

Appellate Information

  • Decided 11/09/2012
  • Published 11/09/2012



  • California Court of Appeal


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