HOME
 


Ethical and Legal Responsibilities
of Virginia Mental Health Professionals
in Response to a Subpoena

Mary Alice Fisher, Ph.D

Virginia's therapist-patient privilege statute is much less protective of client confidentiality than those in most other states (Glosoff et al., 1997). (See Note 1.) This means that communications between Virginia therapists and their patients are less protected in court cases than would be true in most states. This, in turn, means that Virginia attorneys are accustomed to seeking information or testimony from mental health professionals, especially in child custody cases (Coughter & Tweel, 2002). It is therefore especially important for Virginia mental health professionals to understand their ethical responsibilities and to know how to exercise their legal options when they receive a subpoena.

First, it is important to know the legal difference between a subpoena (which can be issued by an attorney) and a court order (issued by a judge). Contrary to the legal advice they might receive from the attorney issuing the subpoena (and sometimes even from the client's attorney), unless the client has signed a consent form authorizing release of the information, therapists have both an ethical responsibility (APA Committee on Legal Issues, 2006; Bennett et al., 2006; Koocher & Keith-Spiegel, 2008) and a legal responsibility ( Fairfax Hospital v. Curtis, 1997; U.S. Department of Health & Human Services, 2009) to notify the client and to see that someone files a motion requesting that the judge quash the subpoena. Filing the "motion to quash" permits a judge to make the final decision about whether disclosure is legally required, either by quashing the subpoena and issuing a protective order, or by issuing a court order requiring that the information be disclosed.

Upon receipt of a subpoena, Koocher & Keith-Spiegel (2008) recommend that you ". . . contact your client, explain the situation, and ask for permission to talk with his or her attorney . . . ." (p. 210). That conversation with the client's attorney should be initiated only with the client's written consent. If the client does not wish the information to be disclosed in response to the subpoena, the conversation with the attorney should include a discussion of filing a motion asking the judge to quash the subpoena.

Once a motion to quash has been filed (whether by you, your attorney, or the client's attorney), Virginia judges have some very broad options for protecting mental health records under the Health Records Privacy Statute (see §32.1-127.1:03; paragraph H, 6). For example, judges may now consider: (1) the specific purpose for which the information was collected; (2) the degree to which disclosure would embarrass, injure, or invade the privacy of the individual; (3) the effect of the disclosure on the individual's future health care; (4) the importance of the information to the lawsuit or proceeding; and (5 any other relevant factor. Remind the attorney to use these and other relevant arguments when filing the motion . (See Note 2.)

Finally, in preparing for that conversation with the client's attorney, remember that attorneys are not always aware of your professional and ethical obligations about subpoenas, and they may therefore suggest that a motion to quash does not need to be filed. However, unless the patient has made an informed decision to release the information and has given you written consent to release it, you have no ethical basis for disclosing the information unless a judge so orders.

Consider the advice below from a risk-management handbook published by a malpractice insurer, the APA Insurance Trust (Bennett et al., 2006) :

 

"In general, a psychologist may only disclose information with the consent of the patient or in response to a court order.  The receipt of a subpoena alone without the consent of the patient does not override this requirement. A court order, however, overrides the need to obtain patient consent. . . . [ emphasis added ].
       " Psychologists are required to respond to a subpoena, but they are prohibited from releasing records merely upon the receipt of a subpoena.   In most instances, the psychologist should inform the requesting party, in writing, that the receipt o f a release of information form (authorization) signed by the patient is required prior to releasing information in response to a subpoena. . . [ emphasis added ]
       "Unfortunately, many attorneys do not understand that psychologists have limited discretion for releasing records.  Attorneys representing patients (or sometimes attorneys representing parties adverse to the patient's interests) may misinform psychologists of their legal obligations and instruct them to release records in response to a subpoena alone.  Do not be bullied by these tactics.  It is best to seek legal consultation in situations in which the requirements are unclear. ... A court order issued by the presiding judge does compel the release of records or testimony as specified in that order . . . " ( p. 111)

REFERENCES
American Psychological Association Committee on Legal Issues. (2006) “Strategies for Private Practitioners Coping With Subpoenas or Compelled Testimony for Client Records or Test Data. Professional Psychology: Research and Practice, 37 (2), 215-222.

Bennett, B.E., Bricklin, P.M., Harris, E., Knapp, S. VandeCreek, L., & Younggren, J.N. (2006) Assessing and Managing Risk in Psychological Practice: An Individualized Approach . Rockville, MD, American Psychological Association Insurance Trust.

Coughter, E. P. & Tweel, R. R. (2002) Family Law. U. Richmond Law Review 37, 155-198. (Discussing provisions of the now-repealed privilege statute, § 20-124.3:1.)

Fairfax Hospital v. Patricia Curtis (1997). Virginia Supreme Court Record #962068, October 31, 1997.

Glosoff, H.L., Herlihy, S.B., Herlihy, B. & Spence, E.B. (1997) Privileged Communication in the Psychologist-Client Relationship. Professional Psychology: Research and Practice, 28, 573-581.

Koocher, G.P. & Keith-Spiegel, P. (2008). Ethics in Psychology and the Mental Health Professions:  Standards and Cases, Third Edition. New York, Oxford University Press

U.S. Department of Health & Human Services.(2009).Court Orders and Subpoenas [Under HIPAA]. See at http://www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/courtorders.html

=================
Note 1. In fact, 13 states model their therapist- patient privilege statute after their attorney-client privilege statute. See discussion and text of those statutes at http://www.CenterForEthicalPractice.org/PrivilegeLaws.htm

Note 2. For examples of other possible arguments to use, see http://www.centerforethicalpractice.org/Form-MotionToQuash.htm

April, 2009

HOME