Ellis v. Ellis
This is an appeal by Mary Helen Marshall Ellis, the wife, from a Shelby County Circuit Court decree granting a divorce to Henry C. Ellis, the husband, on grounds of cruel and inhuman treatment. The wife raised numerous assignments of error, including the trial court's exclusion of evidence regarding the husband's income, the inadmissibility of certain expert and investigative reports, and the disallowance of psychiatrist Dr. Mark Ivie's testimony due to patient privilege. The appellate court affirmed the trial court's decision, finding that the income evidence exclusion was harmless error, and upholding the psychiatrist-patient privilege even when a spouse was present during consultations. The court also found sufficient evidence to support the finding that the wife was guilty of cruel and inhuman treatment and that the defense of recrimination was properly considered.