Arizona Supreme Court

In Re: Mh2023-004502

February 11, 2026

Summary

The court held that the patient’s communications with a social worker during a one-time preliminary assessment were not protected by the behavioral health professional-client privilege because no confidential professional-client relationship existed. The court declined to decide whether the social worker could testify as an acquaintance witness because that issue was moot after the treatment order expired, but it exercised discretion to decide the recurring privilege issue. The court vacated the court of appeals’ opinion and affirmed the superior court’s ruling.