Legal Opinion

St. John v. Napolitano

District Court, District of Columbia

Decided March 31, 2011No. Civil Action No. 2010-0216PublishedCited by 21 opinions

1Opinion of the Court

MEMORANDUM OPINION

BERYL A. HOWELL, District Judge.

The defendant in this employment discrimination action has moved to compel discovery of the plaintiffs medical records, including any records of mental health treatment. This motion presents the Court with a question which frequently arises in employment discrimination cases but which has led to divergent outcomes in the courts: Does a plaintiff automatically waive the psychotherapist-patient privilege merely by asserting that the defendant’s actions caused the plaintiff to experience emotional distress? For the reasons that follow, the Court…

2Cases cited17 opinions

  1. Jaffee v. RedmondSupreme Court of the United States · 1996
  2. Sims v. BlotCourt of Appeals for the Second Circuit · 2008
  3. Deborah L. Schoffstall v. William Henderson, Agent U.S. Postal ServiceCourt of Appeals for the Eighth Circuit · 2000
  4. Food Lion, Incorporated v. United Food and Commercial Workers International Union, Afl-Cio-Clc, United Steelworkers of America, Afl-Cio-ClcCourt of Appeals for the D.C. Circuit · 1997
  5. Harold D. Johnson, M.D. v. Greater Southeast Community Hospital CorporationCourt of Appeals for the D.C. Circuit · 1991

12 more not listed; retrieve them via the Exa API.

3Cited by21 opinions

  1. Flowers v. OwensDistrict Court, N.D. Illinois · 2011
  2. Awalt v. MarkettiDistrict Court, N.D. Illinois · 2012
  3. Aubri Vahai v. Ryan GertschWyoming Supreme Court · 2020
  4. Coleman v. District of ColumbiaDistrict Court, District of Columbia · 2011
  5. Magney v. PhamWashington Supreme Court · 2020

16 more not listed; retrieve them via the Exa API.

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