P0880 Constitutional rights to freedom of religion do not bar discovery of church documents concerning the counseling of an errant priest pursuant to subpoenas issued under a valid and neutral law of general applicability; the privilege for clergypenitent communications does not apply to communications that all parties involved understood would be subject to the church's declared policy of routinely sharing such communications with other church employees; the psychotherapistpatient privilege does not apply to communications that all parties involved understood would be disclosed to other church employees for purposes other than advancing therapy.CitationROMAN CATHOLIC ARCHBISHOP v SUPERIOR COURT (Church Subpoenas) 131 CA4 417 [See: EvC 1032, 911, 1012, 992; Emp Div v Smith 494 US 872; Grosslight v Superior Court 72 CA3 502]
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