Matthew Longfellow v. Robinson's Wharf, Inc.

Summary

The United States District Court for the District of Maine addresses whether a plaintiff’s mental health records are protected by the psychotherapist-patient privilege in an employment-termination action. The court holds that the plaintiff’s representation that he seeks only garden-variety emotional distress damages does not waive the privilege and denies the request for privileged records, while noting that certain treatment-related information may not be privileged.

Holdings

1. A plaintiff's unequivocal claim for only garden-variety emotional-distress damages does not waive the psychotherapist-patient privilege.
2. The Court declined to order disclosure based on asserted relevance to non-damages issues where Plaintiff was not claiming that the termination-related conduct resulted from medication or a mental-health condition.

Questions Presented

1. Whether Plaintiff's claim for garden-variety emotional-distress damages waived the psychotherapist-patient privilege.
2. Whether Defendant was entitled to Plaintiff's mental health records based on their asserted relevance to issues other than damages.

Disposition

other