Privilege protecting the confidentiality of communications between psychologists and their patients

United States v. Alvarez, 584 F.2d 694, 701 (5th Cir. 1978) (reversing conviction for heroin trafficking because the trial court erroneously admitted principal witness's in-court testimony of the out-of-court statements....If a statement is offered against a criminal defendant, the statement qualifies as a statement against interest for purposes of the federal hearsay exception for statements against interest only if there is corroborating evidence of the trustworthiness of the statement.

Cf. United States v. Nguyen, 465 F.3d 1128, 1132 (9th Cir. 2006) (reversing conviction for willful failure to comply with the terms of a release under supervision agreement because the trial court erroneously admitted into....An exception to the hearsay rule applies to the following records of government offices and agencies: (A) public records that set forth the activities of the government office or agency; (B) public records that set forth observations that a government office or agency was required to make and report but this exception does not apply in criminal cases to observations of police officers and other law enforcement personnel; or (C) in civil actions and proceedings and in criminal cases when offered against the government, factual findings resulting from an investigation made pursuant to authority granted by law, unless the sources of information or other circumstances indicate the untrustworthiness of such findings.

Hall v. Commissioner, 729 F.2d 632, 634-635 (9th Cir. 1984) (holding that the tax court properly excluded the undated annual contribution statement as a business record because no foundation was laid by a qualified....The exception created by Federal Rule of Evidence 803(11) for religious records applies only if the record was created near the time of the recorded act.