In Re Crisis Connection, Inc., 949 N.E.2d 789

Crisis Connection provides counseling services to victims of domestic violence and sexual assault in several Indiana counties.
Fromme, charged with two counts of child molesting, sought Crisis Connection records relating to the alleged victims M.Y. and D.Y. and their mother.
Crisis Connection asserted the victim advocate privilege under I.C. 35-37-6-9 to prevent disclosure of confidential records.
The Dubois Circuit Court ordered Crisis Connection to deliver records to the court for in camera review for relevance.
The Court of Appeals held the privilege applied and directed the records be treated as privileged, with in camera review possible under limited circumstances.
The Supreme Court granted transfer to decide whether the victim advocate privilege prevents disclosure and whether constitutional rights override the privilege.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Indiana's victim advocate privilege apply to Crisis Connection's records?	Crisis Connection records are protected by the privilege and cannot be disclosed.	Privileged status may be outweighed by defendant's rights to a defense, including access to evidence.	Yes; the privilege applies and bars disclosure.
Do Fromme's constitutional rights override the victim advocate privilege to obtain the records?	Privilege should stand unless a constitutional right requires disclosure.	Confrontation, due process, and compulsory process rights require access to the records for defense.	No; privilege remains controlling; no constitutional right to in camera review overrides it.
Is the three-step discovery test for nonprivileged information applicable to privileged records here?	The test should allow in camera review if records are relevant and material.	Privileged information is categorically off-limits; the three-step test does not apply.	Inapplicable to privileged information; privilege dictates outcome.
Does Ritchie require disclosure of privileged material under due-process or compulsory-process analysis?	Ritchie suggested balancing and potential disclosure where relevant to defense.	Indiana's privilege excludes such balancing for state-protected confidential information.	Ritchie does not compel disclosure; privilege is upheld and applied.

Pennsylvania v. Ritchie, 480 U.S. 39 (U.S. 1987) (Confrontation, due process, and privilege interaction; plurality on pretrial disclosure)
Weatherford v. Bursey, 429 U.S. 545 (U.S. 1977) (No general constitutional right to discovery in criminal cases)
Roviaro v. United States, 353 U.S. 53 (U.S. 1957) (balancing of public interest in information vs. defense access)
Crane v. Kentucky, 476 U.S. 683 (U.S. 1986) (balancing exculpatory evidence against justification for exclusion)
Kubsch v. State, 784 N.E.2d 905 (Ind. 2003) (due process right to present a complete defense)
Jaffee v. Redmond, 518 U.S. 1 (U.S. 1996) (establishes psychotherapist-patient privilege; confidentiality importance)