California, United States of America
The following excerpt is from Arias, In re, 230 Cal.Rptr. 505, 42 Cal.3d 667, 725 P.2d 664 (Cal. 1986):
1 I am aware of no case which addresses the question whether section 636 was intended to protect the confidentiality of group counseling sessions by a religious advisor, as contrasted with one-on-one confessions or conversations. In the somewhat analogous context of the priest-penitent privilege, the relevant statute defines the privileged "penitential communication" to mean "a communication made in confidence, in the presence of no third person so far as the penitent is aware." (Evid.Code, 1032; cf. Simrin v. Simrin (1965) 233 Cal.App.2d 90, 43 Cal.Rptr. 376.)
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