Quaaludes Prescription Case
In In re Doe (2d Cir. 1983) 711 F.2d 1187, a psychiatrist who saw 70 patients a day and prescribed Quaaludes for over 90 percent of his patients, attempted to resist a grand jury subpoena duces tecum by asserting a psychotherapist-patient privilege.
While the court did not doubt the patients' interest in keeping the relationship confidential, it disagreed the privilege should be recognized on the facts of the case.
In so ruling, the court noted there was little, if any, evidence any genuine therapy took place. Id. at p. 1193.