In State ex rel. Hope House, Inc. v. Merrigan, the Missouri Supreme Court examined Missouri Revised Statutes Section 210.140, 5 which eliminates legally recognized privileged communications where there is evidence of child abuse or neglect, and attempted to resolve it with Section 455.220,6 which establishes strict confidentiality for residents of domestic violence shelters. 7 Although Section 210.140 has previously been the subject of litigation, this case was the first time the court concurrently dealt with Section 455.220 and attempted to harmonize two conflicting statutes that ultimately could have a tremendous effect on the children involved. This Note will examine the potential impact of the court's ruling on battered women, their children, and the shelters trying to help these victims. This Note will also weigh the benefits and detriments of allowing victims' records to be kept confidential, even when children are involved and the potential for child abuse is present.

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