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Armsteadv.State

CourtSupreme Court of Georgia
Docket No.S13A0611
DecidedJune 17, 2013
Reporter293 Ga. 243; 744 S.E.2d 774; 2013 Fulton County D. Rep. 1852; 2013 WL 2928857; 2013 Ga. LEXIS 544
JudgesSupreme Court of Georgia
Tags
CriminalCriminal ProcedureConstitutional LawEvidenceFourth AmendmentDue ProcessMotion for New TrialStatutory Interpretation
Case Summary

Craig Armstead was convicted of murder and related crimes after killing a coworker. He intended to rely on an insanity defense, and the State subpoenaed mental-health records created while he was held in the county jail, where he had been placed on a psychiatric ward and monitored after expressing suicidal and homicidal urges. Armstead moved to exclude the records, arguing that their disclosure violated Georgia’s privacy protections, psychiatrist-patient privilege, and the Fourth Amendment. The Supreme Court of Georgia affirmed. Georgia privacy and privilege protections for mental-health records are not absolute, and a defendant waives the protections for relevant records by placing mental capacity in issue in a criminal proceeding. Armstead’s notice of intent to pursue an insanity defense did exactly that. The court also held that the records arose from jail screening and custodial monitoring rather than treatment Armstead had independently sought, leaving him with little expectation of privacy in the communications. The State obtained the records only after the insanity defense was asserted. The trial court therefore properly denied both the motion in limine and the motion for new trial. The judgment was affirmed.

Opinion

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