California, United States of America
The following excerpt is from Grosslight v. Superior Court, 140 Cal.Rptr. 278, 72 Cal.App.3d 502 (Cal. App. 1977):
[72 Cal.App.3d 506] It is true that confidential communications have been statutorily defined as communications between the psychotherapist and 'patient,' 3 and the parents herein are not literally 'the patient.' It is also true, as RPI contends, that the attorney-client privilege does not protect information coming from a third party who is not a client unless the person is acting as the client's agent. (People v. Lee (1970) 3 Cal.App.3d 514, 527, 83 Cal.Rptr. 715.) We find it unnecessary to determine whether petitioner's parents were acting as her agent, so as to bring the parents' communications under the above exception in People v. Lee. Also, the fact that the parents are not literally the patient is not crucial.
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