Cited by

(“[T]he medical privilege, like other privileges, sometimes must give way to the defendant’s right to confront his accusers.” (quoting State v. Kutchara, 6 )).

Without analysis, however, we have reiterated in dicta a statement we made pre-Ritchie—that all privileges must sometimes give way to a criminal defendant’s right to confront their accuser.7 see also Hummel, d at 71.

A crime victim’s past medical records ar e “generally protected from disclosure by the physician-patie nt privilege.” State v. Kutchara , see Minn. Stat. § 595.02, subd.

Although we conclude that the district court’s order for in camera revi ew is unauthorized for a different reason, we note that the supreme court has held that privileges “‘sometimes must give way to a defendant’s right to confront his accusers.’” (quoting State v. Kutchara , (M inn.

Lastly, Jefferson asserts that “the character evidence improperly elicited was particularly damaging.” The supreme court has said that, if prior -bad-act evidence “did not tend to show that [the] defendant was guilty of another crime, the chance of it creating unfair prejudice was less than is ordinarily the case when evidence is admitted under Rule 404(b).” State v. Kutchara , see State v. Chambers , (stating the same).

“A crime victim’s past medical records ar e generally protected from disclosure by the physician-patient privilege.” see Minn. Stat. § 595.02, subd.

But “the medical privilege ‘sometimes must give way to a defendant’s right to confront his accusers.’” Evans, d at 872 ().

But “the medical privilege, like other privileges, sometimes must give way to the defendant’s right to confront his accusers.”

But “the medical privilege, like other privileges, sometimes must give way to the defendant’s right to confront his accusers.”

But like other privileges, the medical privilege “sometimes must give way to a defendant’s right to confront his accusers.”

Cram is correct to note that we have recognized that privileges “ ‘sometimes must give way to the defendant’s right to confront his accusers.’ ” ().

However, “the medical privilege, like other privileges, sometimes must give way to the defendant’s right to confront his accusers.”

Where evidence sought to be introduced under Spreigl does not tend to show that the defendant is guilty of a crime other than the crime with which he is charged, “the chance of it creating unfair prejudice [is] less than is ordinarily the case when evidence is admitted under Rule 404(b).”

(defendant’s request for in camera review of mental health records was properly denied by district court due to defendant’s failure to show how records could be rele vant to his defense); (in camera review of welfare department records ordered); (while privilege not to disclose past medical records must sometimes give way to defendant’s right to confront his accusers, in camera review of medical records by district court did not reveal any relevant information).

(upholding trial court’s in camera review of victim’s prior medical records and its refusal to make those records available to defendant); -59 (Minn.App.1985) (upholding in camera review of victim’s medical records), review denied (Minn. Dec.

where we held that an aggravated assault and an attempted aggravated robbery were part of the same behavioral incident because the assault was committed in furtherance of the robbery.

See, (access to *341 county welfare confidential records); (access to patient’s medical records).

1 “[T]he medical privilege, like other privileges, sometimes must give way to the defendant’s right to confront his accusers.”

(assault with a dangerous weapon and attempted robbery were part of same behavioral incident because assault was in furtherance of the robbery) (attempted robbery and assault with a dangerous weapon were not part of same behavioral incident because defendant

20, 1985) (failure to request specific instructions or object to instructions precludes appellate review) (); (trial court’s failure to give a specific instruction regarding self-defense not plainly erroneous).

where we stated: Defendant next complains about the trial court’s refusal to let him examine the victim’s private medical records going back 5 years to see if there was anything in them that might bear on his claim.

24, 1986); -28 (Minn.1984).

at 549 ; (remanding for in camera review)

(assault with a dangerous weapon and attempted robbery were part of same behavioral incident because assault was in furtherance of the robbery) (attempted robbery *450 and assault with a dangerous weapon were not part of same behavioral incident because defe