Walden Behavioral Care v. K.I.Annotate this Case
K.I. was committed to Walden Behavioral Care (Walden), a facility for the treatment of mentally ill patients, for a three-day period, during which a psychiatrist provided diagnosis of and treatment to K.I. Walden then brought a petition seeking K.I.’s continuing commitment. K.I. filed a motion in limine to exclude the psychiatrist’s testimony regarding K.I.’s statements, asserting that his statements were protected by the psychotherapist-patient privilege, as defined in Mass. Gen. Laws ch. 233, 20B. A district judge denied the motion, determining that the exception provided by section 20B(b) was inapplicable because the psychotherapist-patient privilege was overcome by the imminent harm exception to the privilege set forth in Mass. Gen. Laws ch. 233, 20B(a). At the commitment hearing, the psychiatrist was permitted to testify to K.I.’s statements and to his opinion that K.I. was suicidal. K.I. was committed to Walden for six months. The Supreme Judicial Court affirmed, holding (1) the exception to the psychotherapist-patient privilege established in section 20B(a) applied under these circumstances; and (2) the district court judge did not err in permitting the psychiatrist to testify at the involuntary commitment hearing concerning K.I.’s statements.