In re C.P.

SHEPARD, Chief Justice.

The question is whether patient communications to a counselor who is supervised by a psychiatrist fall within the doctor-patient privilege. We hold that a counselor who aids the psychiatrist is covered by the privilege. By contrast, a counselor who is in fact the caregiver and acts largely independently is not an adjunct to the psychiatrist and thus is not covered by the privilege.

This dispute arose after the State of Indiana filed a delinquency petition concerning C.P., a sixteen year old girl, alleging habitual disobedience, frequently called incorrigibility. Ind.…