In Re Grand Jury Proceedings (Violette)

SELYA, Circuit Judge.

This matter presents an issue of first impression: whether the nascent psychotherapist-patient privilege encompasses a so-called “crime-fraud exception,” parallel to that which we previously have recognized anent the attorney-client privilege. We hold that the privilege entails such an exception and that the exception applies here. We therefore affirm the district courtís order enforcing grand jury subpoenas served upon a pair of psychiatrists.

I. BACKGROUND

To protect the secrecy of ongoing grand jury proceedings, we limit our review of the facts to the bare essentials.…