Summary
This Minnesota Supreme Court opinion addresses whether a mandated-reporter statute requires a therapist to file a maltreatment report when the alleged victim was a minor at the time of the abuse but reached adulthood before the disclosure. The court interprets Minn. Stat. § 260E.06, subd. 1(a), concluding that the reporting requirement applies if the maltreatment occurred within the preceding three years, regardless of the victim's current age. Consequently, the therapist-client privilege is abrogated to the extent necessary for the required report, and the trial court properly admitted the therapist's testimony and report in the appellant's criminal sexual conduct prosecution. The judgment of the court of appeals is affirmed.
Topics
Practice areas
Questions Presented
- Whether Minn. Stat. §260E.06, subd. 1(a) requires a mandatory report when the alleged victim is an adult at the time of disclosure.
- Whether the therapist‑client privilege is abrogated by the mandatory‑reporter statute to the extent of the information required in the report.
- Whether the district court erred in admitting the therapist's report and testimony.
Holdings
- The mandatory‑reporter statute requires a report if the reporter knows or has reason to believe a child was maltreated within the preceding three years, even if the child is an adult when the disclosure is made.
- The privilege is abrogated to the extent that the information is required in the mandatory maltreatment report.
- The district court did not err; the report was mandatory and the privilege was properly abrogated.
Key quotations
“Minnesota Statutes section 260E.06, subdivision 1(a) (2024), requires a mandated reporter to file a maltreatment report if the mandated reporter knows or has reason to believe that a child has been maltreated within the preceding three years, even if the allegedly maltreated child reaches adulthood before the alleged maltreatment is disclosed to the mandated reporter.” (at 1)
Factual background
In June 2021 Martens disclosed to his therapist that he had sexual contact with a babysitter when she was 17. The therapist, a mandated reporter, filed a maltreatment report. The victim was 18 at the time of disclosure. Martens was charged and convicted of third‑degree criminal sexual conduct.
Procedural history
The district court denied Martens's motion to exclude the therapist's report and testimony, a jury convicted him of third‑degree criminal sexual conduct, and the Court of Appeals affirmed. The Supreme Court of Minnesota granted review.