Tracy Will Vaughn v. State of Arkansas

Summary

The court held that the victim’s therapy records were protected by Arkansas’s absolute psychotherapist-patient privilege and that the privilege was not waived by references to therapy-related disclosures, the victim’s testimony, or compelled production of the records. It further held that the defendant’s confrontation, compulsory-process, and due-process rights did not entitle him to pretrial access or an in camera review of records shielded by that privilege. The conviction was affirmed, and the court of appeals’ opinion was vacated.