Crisis Connection, Inc. v. Fromme
Annotate this CaseAfter being charged with two counts of child molesting, defendant Ronald Fromme asked the circuit court to require Crisis Connection, an organization that provides services to victims of sexual abuse and domestic violence, to provide him with all of its records relating to the alleged victims. Crisis Connection argued that the state victim advocate privilege gave it authority to refuse the request. The circuit court ordered Crisis Connection to deliver the records to the court for its in camera review before turning them over to Fromme. Upon review, the court of appeals concluded that he privacy interest asserted by Crisis Connection was not strong enough to bar the in camera review. On appeal, the Supreme Court vacated the decision of the appellate court and reversed the order of the trial court, holding the state's compelling interest in maintaining the confidentiality of information gathered in the course of serving the needs of victims of violence and abuse was not outweighed by Fromme's right to present a complete defense. Accordingly, Fromme did not have a constitutional right to an in camera review of the records. In the absence of a violation of Fromme's constitutional rights, the Court applied the victim advocate privilege.
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