United States v. Robert Allen Romo

McKEOWN, Circuit Judge:

Robert Romo appeals his conviction for threatening the President in violation of 18 U.S.C. § 871(a). Although he confessed to a licensed counselor that he made such a threat, he now claims that the counselor’s trial testimony was admitted in violation of the psychotherapist-patient privilege. We conclude that the testimony was not privileged because Romo’s statements to the counselor did not occur during the course of diagnosis or treatment. We are not persuaded that Romo’s challenge to the testimony of the Director of Mail Analysis for the White House merits reversal,…