State of Minnesota v. Jerry Expose, Jr.

OPINION

CHUTICH, Judge.

Appellant Jerry Expose Jr. appeals his conviction of terroristic threats, arguing that the district court erroneously ruled that an exception to the psychologist-client privilege exists for threatening statements made by a client to his or her psychologist and that the district court improperly allowed witnesses to testify about privileged information. Because Expose’s communications with a therapist qualify under the psychologist-client privilege statute and no “threats exception” to the privilege exists in Minnesota, we reverse Expose’s conviction and remand.

FACTS

In…