The U.S. Supreme Court first recognized the "psychotherapist privilege" in Jaffee v. Redmond, 518 U.S. 1 (1996). The privilege—which applies in both civil and criminal cases—protects communications between a patient and his or her mental health provider made in the course of seeking or receiving diagnosis or treatment. The privilege is meant to promote effective psychotherapy by fostering an atmosphere of confidence and trust in which a patient is willing to make a full and frank disclosure of facts, emotions, memories, and fears. Although the existence of the privilege is well-settled, little case law exists addressing the scope of the "communications" that are covered by the privilege—and, in particular, whether (and, if so, to what extent) the privilege protects nonverbal communications.