State of Minnesota, Respondent, vs. Ryan James Martens, Appellant

Summary

The court held that the mandated-reporter statute requires a therapist to report suspected maltreatment that occurred within the preceding three years when the victim was a child at the time of the maltreatment, even if the victim is an adult when the disclosure is made. Because the report was mandatory, the therapist-client privilege was abrogated to the extent of information required in the report, and the district court did not abuse its discretion by admitting the report and related testimony. The court therefore affirmed the court of appeals and Martens’s conviction.