People v. Sevedo

Contemnors, a domestic violence advocacy center and its executive director, appeal civil and criminal contempt orders entered against them based on their refusal, pursuant to statutory privilege for domestic violence advocates and victims, to produce documents for in camera judicial review. Advocacy center had been providing services to Defendant, who had been charged with armed robbery. Defendant's alleged threat to harm detective was communicated to advocate in course of advocate providing information, counseling, or advocacy, and thus, advocate-victim privilege applied to prevent disclosure of confidential communication in State's prosecution of Defendant for threatening a public official.An in camera review was unnecessary to determine whether documents sought fell within scope of privilege. Contempt order reverse, and fine imposed on contemnors vacated. (HALL, concurring; GORDON, specially concurring.)