Cummings v. Summa Health Sys.

2024 Ohio 5796, 259 N.E.3d 119
CourtOhio Court of Appeals
DecidedDecember 11, 2024
Docket30969
StatusPublished

This text of 2024 Ohio 5796 (Cummings v. Summa Health Sys.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cummings v. Summa Health Sys., 2024 Ohio 5796, 259 N.E.3d 119 (Ohio Ct. App. 2024).

Opinion

[Cite as Cummings v. Summa Health Sys., 2024-Ohio-5796.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF SUMMIT )

MARIAN CUMMINGS, et al. C.A. No. 30969

Appellees

v. APPEAL FROM JUDGMENT ENTERED IN THE SUMMA HEALTH SYSTEM, et al. COURT OF COMMON PLEAS COUNTY OF SUMMIT, OHIO Appellants CASE No. CV-2020-11-3207

DECISION AND JOURNAL ENTRY

Dated: December 11, 2024

STEVENSON, Presiding Judge.

{¶1} Defendants-Appellants Summa Health System, Summa Health System Corp.,

Summa Health System Community, Summa Health, Summa Physicians, Inc. DBA Summa Health

Medical Group, and Kevin L. Mayor, M.D. (collectively “Summa”) appeal the judgment of the

Summit County Court of Common Pleas that granted Plaintiffs-Appellees Mariann Cummings,

Carol House, Kimberly House, and Andrea House’s (collectively “Cummings”) motion to compel

discovery. For the reasons set forth below, this Court affirms.

I.

{¶2} This case arises from a medical malpractice suit filed by Cummings alleging that

as a result of Summa’s negligence, Mariann Cummings was misdiagnosed with lung cancer and

underwent an unnecessary lobectomy of her upper-right lung after her biopsy tissue sample was

cross-contaminated with that of another patient. The parties refer to that other patient as “Patient

C.” 2

{¶3} Cummings propounded written discovery requests upon Summa regarding the

processing of Patient C’s tissue sample. The particular discovery requests at issue in this appeal

are Interrogatory Nos. 4-7 and 9-11 of Cummings’ second set of Interrogatories, Interrogatory

No. 8 of Cummings’ third set of Interrogatories, and Requests for Admission Nos. 3-7 of

Cummings’ third set of Requests for Admission, which are as follows:

Identify the time, date, and place that Mariann Cummings’ specimen from the August 31, 2019, biopsy tissue was grossed, embedded, and cut in relation to Patient C, specimen from the procedure that resulted in the tissue that contaminated Cummings’ slides.

Were Mariann Cummings’ and Patient C’s specimens ever in the same place, and if so, when?

Identify where and when Patient C had her procedure as compared to Mariann Cummings’ August 31, 2019, biopsy that resulted in the tissue that contaminated Cummings’ slides.

Identify whether Patient C’s procedure that resulted in the tissue that contaminated Mariann Cummings’ slides had any of the same people present in the room as Mariann Cummings’ August 31, 2019, biopsy, and if so, identify all such individuals.

Identify who grossed, embedded, and cut Patient C’s specimen from the procedure that resulted in the tissue that contaminated Mariann Cummings’ slides.

Identify the specific time difference between when Mariann Cummings’ August 31, 2019, biopsy specimen was grossed and when Patient C’s specimen was grossed that same day.

Admit a specimen from Patient C was grossed on September 3, 2019.

Admit a specimen from Patient C was grossed on September 3, 2019, by John Kuntz.

Admit Mariann Cummings’ August 31, 2019, biopsy specimen and a specimen from Patient C were grossed back-to-back.

Admit Mariann Cummings’ August 31, 2019, biopsy specimen and a specimen from Patient C were grossed sequentially.

Admit Mariann Cummings’ August 31, 2019, biopsy specimen and a specimen from Patient C were grossed by the same person on September 3, 2019. 3

Admit Mariann Cummings’ August 31, 2019, biopsy specimen and a specimen from Patient C were grossed within five minutes of each other.

Admit Mariann Cummings’ August 31, 2019, biopsy specimen and a specimen from Patient C were grossed within ten minutes of each other.

{¶4} Cummings sought this information to rebut Summa’s position that the cross-

contamination was not the result of negligence, but instead, is something that occasionally just

happens. Cummings wanted to investigate the lab process to determine where the contamination

occurred and if it constituted negligence. To each request, Summa objected that the information

sought was protected by physician-patient privilege under R.C. 2317.02(B)(1).

{¶5} Cummings moved to compel Summa to respond. Summa opposed the motion and

moved for a protective order. Following a hearing, the trial court granted Cummings’ motion and

ordered Summa to produce answers to the above requests. In its ruling, the trial court reasoned as

follows:

As to the information [Cummings] seek[s] relating to where and when Patient C’s sample was grossed, embedded, and cut, where and when her procedure took place relative to [Cummings’], and the people present (included who grossed, embedded, and cut the sample), Summa has not established that this information came from a conversation between a patient and their doctor, relates to diagnosis or treatment, or was necessary to enable a physician, advanced practice registered nurse, or dentist to diagnose, treat, prescribe, or act for a patient. Therefore, Summa has failed to meet its burden of proving that a privilege applies to the requested information. The information is discoverable.

{¶6} Summa timely appealed and asserts one assignment of error for our review.

II.

ASSIGNMENT OF ERROR

THE TRIAL COURT COMMITTED REVERSIBLE ERROR WHEN IT COMPELLED [SUMMA] TO PRODUCE INFORMATION ABOUT THE GROSSING, EMBEDDING, AND CUTTING OF A NON-PARTY PATIENT’S BIOPSY TISSUE AND DENIED [SUMMA’S] MOTION FOR A PROTECTIVE ORDER BASED ON THE PATIENT-PHYSICIAN PRIVILEGE CODIFIED IN OHIO R.C. 2317.02(B). 4

{¶7} “Ordinarily, a discovery dispute is reviewed under an abuse-of-discretion standard.

. . .However, if the discovery issue involves an alleged privilege . . . it is a question of law that

must be reviewed de novo.” Ward v. Summa Health Sys., 2010-Ohio-6275, ¶ 13. Furthermore,

cases such as this one involving the interpretation of a statute are a matter of law that an appellate

court also reviews under a de novo standard. Akron Centre Plaza, L.L.C v. Summit Cty. Bd. of

Revision, 2010 Ohio 5035, ¶ 10. Therefore, our review of this matter is de novo.

{¶8} “In general, a person’s medical records are confidential.” Hageman v. Southwest

Gen. Health Ctr., 2008-Ohio-3343, ¶ 9. Physician-patient privilege has been codified in R.C.

2317.02 to deny the use of a person’s confidential medical records in litigation except in limited

circumstances. Id. R.C. 2317.02(B)(1) sets forth the scope of the physician-patient privilege as

The following persons shall not testify in certain respects:

A physician, advanced practice registered nurse, or dentist concerning a communication made to the physician, advanced practice registered nurse, or dentist by a patient in that relation or the advice of a physician, advanced practice registered nurse, or dentist given to a patient, except as otherwise provided in this division, division (B)(2), and division (B)(3) of this section, and except that, if the patient is deemed by section 2151.421 of the Revised Code to have waived any testimonial privilege under this division, the physician or advanced practice registered nurse may be compelled to testify on the same subject.

{¶9} Pursuant to R.C. 2317.02(B)(5)(a) “communication” means:

acquiring, recording, or transmitting any information, in any manner, concerning any facts, opinions, or statements necessary to enable a physician, advanced practice registered nurse, or dentist to diagnose, treat, prescribe, or act for a patient.

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Bluebook (online)
2024 Ohio 5796, 259 N.E.3d 119, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cummings-v-summa-health-sys-ohioctapp-2024.