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Appeals court weighs whether in‑camera review of medical records is warranted in State v. Wardle
Summary
In State v. Wardle (No. 20230761) the Court of Appeals considered whether defense counsel met the three‑part Rule 506 test to overcome the medical/therapy privilege — alleging a recovered/repressed memory and arguing medical or therapy records are reasonably certain to contain evidence that could undermine the complainant's reliability.
The Utah Court of Appeals heard argument in State v. Wardle (No. 20230761) on an interlocutory issue: whether trial counsel established the threshold showing required by Rule 506 (medical/therapy privilege) to obtain an in‑camera review of the complainant’s medical and therapy records.
Sarah Carlquist, representing Mr. Wardle, asked the panel to remand for in‑camera review, saying the complainant’s police disclosures — including that she "blocked this incident out of my mind and recently remembered…
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