Here, the ACLU filed an amicus brief on behalf of former anonymous patients ("Jane Doe"s) of a fraudulent psychotherapist named James Edward Yates, M.D. The patients were requesting the return of certain documents, concerning them and their psychiatric relationship with Yates, obtained via search warrant pursuant to an investigation of Yates by the California Department of Justice (one of whose members is the named James Naylor) and the Medi-Cal Fraud Unit staff. The ACLU wished to prohibit the use of these confidential documents in court by Yates, as well as prohibit any use of this extremely private information in court. The return of the documents to Yates would also preclude any legal action brought against him by former patients, as Yates would have in his possession the documents necessary for proof.

Yates had been accused of offering to pay his female Medi-Cal patients $20 to have sex with his male non-Medi-Cal patients, as well as "fraudulently billing Medi-Cal for 50-minute individual psychotherapy sessions while actually rendering shorter sessions of group therapy, usually with unlicensed therapists instead of Dr. Yates." The ACLU wrote "The ACLU is deeply troubled by the accelerating encroachment on personal privacy presented by law enforcement techniques, including search warrants for the purposes of obtaining information protected by constitutional and statutory restrictions." The outcome of this case is not known from the available materials.