BRIAN JAMES LAFOREST
v.
DANIELLE DEANNE LAFOREST

Fla. 4th DCA | 2019-12-11
No. 19-2189
Niemeyer, Motz, Floyd
Florida District Court of Appeal, Fourth District (2019) Positive Treatment
Cited by 1 case

AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.

Holding

A trial court must conduct a mandatory in camera inspection of mental health treatment records before ordering their disclosure to ensure only relevant documents are produced.

Headnotes

[1] Mental health treatment records in family law proceedings require a mandatory in camera inspection by the trial court before disclosure to ensure that only relevant docum…

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Key Quotes

“The trial court departed from the essential requirements of law in failing to provide for the mandatory in camera inspection to ensure that only relevant documents and information are disclosed.”

Court's explanation of why it quashed the trial court's order
Facts & Procedural History

In a family law case, the trial court ordered a husband to disclose his mental health treatment records to his wife. The husband sought certiorari rev…

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Topics
In Camera Inspection Writ Of Certiorari

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Opinion of the Court

PER CURIAM. We grant the husband’s petition for writ of certiorari in part and quash the trial court’s order requiring disclosure of his mental health treatment records. The trial court departed from the essential requirements of law in failing to provide for the mandatory in camera inspection to ensure that only relevant documents and information are disclosed. Zarzaur v. Zarzaur, 213 So. 3d 1115, 1120 (Fla. 1st DCA 2017). The court may order production in a manner that allows for in camera review. Petition granted in part and denied in part. CIKLIN, CONNER and KLINGENSMITH, JJ., concur. * * * Not final until disposition of timely filed motion for rehearing.

Cases With Similar Vibessemantic neighbors from the corpus

Citator

Cited By

  • ERN v. Springer (Fla. 4th DCA 2021)
    …on or in camera inspection to ensure that only relevant information is disclosed connecting the mental health records either in substance or time to the claim at issue. This departs from the essential requirements of law. See Laforest v. Laforest, 284 So. 3d 1099, 1099-1100 (Fla. 4th DCA 2019) (citing Zarzaur v. Zarzaur, 213 So. 3d 1115, 1120 (Fla. 1st DCA 2017)); Brown v. Montanez, 90 So. 3d 982, 988 (Fla. 4th DCA 2012); McEnany v. Ryan, 44 So. 3d 245, 247 (Fla. 4th DCA 2010). We grant relief without preju…

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