People v. Soron.

2026 CO 3. No. 25SA203. Physician-Patient Privilege—Child Abuse Exception to Physician-Patient Privilege.

January 12, 2026

In this interlocutory appeal, the People challenged the suppression of certain hospital records, a police officer’s body-worn camera video, and the officer’s notes of proceedings at a hospital. The supreme court concluded that the trial court correctly determined that (1) hospital records created when Soron and her deceased newborn child were found behind a store and taken to a hospital were protected by the physician-patient privilege, and (2) the child abuse exception to that privilege did not apply because that exception relates only to testimony, not to documents. The court found, however, that additional findings are necessary to determine whether the officer’s body-worn camera video and notes documenting treatment that Soron received at the hospital are protected by the physician-patient privilege and, if so, whether the legislature has narrowed that privilege based on other policy interests.

Accordingly, the court affirmed in part and reversed in part the trial court’s suppression order, and the court remanded this case to the trial court for further proceedings.