Center for Legal Advocacy v. Hammons,
323 F.3d 1262 (10th Cir. 2003)

The United States Court of Appeals for the Tenth Circuit held that a Protection and Advocacy System ("P&A Entity") was entitled to peer review records regarding four suicides at a Colorado mental health facility, despite the existence of a state statute shielding peer review from discovery. P&A Entities are designated in each state pursuant to the federal Protection and Advocacy for Mentally Ill Individuals Act of 1986. The Act states that P&A Entities have the authority to "investigate incidents of abuse and neglect of individuals with mental illness," and that such entities also have a statutory right to "all records" regarding the care of the individuals. The court found that the broad language in the Act giving P&A Entities access to "all records" included peer review records protected by state law.