Evidence: "Dangerous Patient" Exception to Psychotherapist-Patient Privilege Permits Psychiatrists to Testify Against Their Patients-United States v. Chase1-The U.S. Court of Appeals for the Ninth Circuit held that there is a "dangerous patient" exception to the psychotherapist's obligation of confidentiality, which permits a psychiatrist to testify against a patient.2 The appellant, Steven Gene Chase, argued that the trial court erred when it permitted his psychiatrist to testify against him concerning threats he made in the course of diagnosis and treatment.3 The district court held that the psychotherapist-patient privilege was inapplicable because the psychiatrist, Dr. Kay Dieter, had …