Hall v. Flannery – May 2015 (Summary)

PEER REVIEW PRIVILEGE

Hall v. Flannery, Case No. 3:13-cv-914-SMY-DGW (S.D. Ill. May 1, 2015)

The United States District Court for the Southern District of Illinois ruled against a hospital that argued that audit logs for a patient’s medical records were protected by the state’s peer review statute. The plaintiff patient alleged that she received two different medical charts in her medical record during discovery. The plaintiff then requested the audit log of her medical record to determine who had the ability to edit her records. The defendant hospital argued that the medical record’s audit logs are protected by the state’s peer review statute.

The court ordered the hospital to turn over the audit log because audit logs are created in the hospital’s ordinary course of business and not specifically for a peer review committee.