Rogers v. State

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Justia Opinion Summary

Appellant was convicted by a jury of driving under the influence of a controlled substance causing substantial bodily harm. Part of the evidence heard by the jury came from a paramedic who took appellant by ambulance to the hospital. The paramedic testified that appellant confided he had smoked marijuana before the accident. Appellant argued that his statement to the paramedic was inadmissible because it was protected by Nevada’s doctor-patient privilege. The district court rejected the argument. The Supreme Court affirmed, holding that the term “doctor,” as defined in Nev. Rev. Stat. 49.215(2), does not include EMTs or paramedics, and thus the doctor-patient relationship required for the privilege to attach did not arise simply because appellant spoke to the paramedic in confidence. The Court also held that the statement was not privileged under Nev. Rev. Stat. 49.225, which protects communications among the patient and persons “under direction of the doctor” because the paramedic was acting as an independent EMT and not under the supervision or direction of a doctor in a doctor-patient relationship with appellant.

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