State v. Lynch
Annotate this CaseThis case required the Supreme Court to reexamine State v. Shiffra, modified by State v. Green, (hereinafter Shiffra/Green), under which a defendant can acquire a complainant’s privileged mental health treatment records via a motion for in camera review if the defendant demonstrates “a reasonable likelihood that the records contain relevant information necessary to a determination of guilt or innocence….” Here the complainant alleged that Defendant sexually assaulted her as a child. Defendant filed a pretrial motion pursuant to Shiffra/Green, seeking an in camera inspection of the complainant’s privileged mental health treatment records. The circuit court granted the motion. Further, the court informed the complainant that if she refused to turn over the records, her testimony would be barred at trial. The complainant refused to give up her mental health treatment records, and the circuit court barred her from testifying at trial. The court of appeals affirmed. The Supreme Court overruled Shiffra/Green and its progeny, holding that Shiffra/Green improperly relied on Pennsylvania v. Ritchie when it invented a right to access privileged information via a motion for in camera review and cannot be grounded in any other legal basis.
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