People v. Torres
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The Supreme Court of the State of Illinois reviewed a case where a defendant, Ramon Torres, was convicted of predatory criminal sexual assault of his four-year-old daughter. The State’s evidence included testimony that Torres tested positive for chlamydia in 2013 and again in 2016. On appeal, Torres argued that his trial counsel was constitutionally ineffective for failing to object to the admission of evidence of these two test results. He maintained that the test results fell under the purview of the physician-patient privilege statute and that none of the statutory exceptions to the physician-patient privilege applied.
This case required the court to interpret the physician-patient privilege statute and whether the test results would have been excluded from evidence at his jury trial had his attorney objected. The appellate court disagreed with Torres and affirmed his conviction and sentence. The Supreme Court of the State of Illinois affirmed the lower courts’ judgments.
The court held that the physician-patient privilege statute did not apply to the 2016 test results as Torres submitted to testing in 2016 not for the purpose of seeking medical treatment, but because he was ordered to do so by the Department of Children and Family Services. Therefore, the privilege and the exceptions to the privilege were irrelevant to the admissibility of the 2016 test results.
Regarding the 2013 test results, the court found that the physician-patient privilege statute does apply. The court, however, determined that the exception set out in subsection (7) authorizes physicians to disclose information subject to the physician-patient privilege “in actions, civil or criminal, arising from the filing of a report in compliance with the Abused and Neglected Child Reporting Act.” Therefore, the 2013 chlamydia test results were admissible even though the physician-patient privilege attached to those test results. The court concluded that the defendant has not satisfied the first prong of the Strickland standard, and his claim of ineffective assistance of counsel fails.
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