Frohn v. Globe Life and Accident Insurance Company

CourtDistrict Court, S.D. Ohio
DecidedMay 12, 2023
Docket1:19-cv-00713
StatusUnknown

This text of Frohn v. Globe Life and Accident Insurance Company (Frohn v. Globe Life and Accident Insurance Company) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Frohn v. Globe Life and Accident Insurance Company, (S.D. Ohio 2023).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION

KAREN FROHN, individually and on behalf of all others similarly situated,

Plaintiff, Case No. 1:19-cv-713 JUDGE DOUGLAS R. COLE v.

GLOBE LIFE AND ACCIDENT INSURANCE COMPANY,

Defendant.

OPINION AND ORDER On March 31, 2023, the Court issued an Opinion and Order granting Defendant Globe Life and Accident Insurance Company’s Motion for Summary Judgment. (Doc. 85). The Court also imposed a temporary seal on that Opinion because it had allowed the parties to file certain exhibits and information relating to that motion under seal. (Docs. 59, 72). In light of that, the Court asked the parties whether they believed portions of the Opinion warranted redaction. Plaintiff Karen Frohn responded by asking the Court to redact references to her late husband Greg Frohn’s various medical ailments (and the activities that contributed to those ailments), as well as information Karen Frohn learned about those ailments from his doctors while they treated him.1 (Doc. 86). Defendant Globe Life, by contrast, said the Opinion did not need redactions. After both a telephone conference to explore the matter more thoroughly and further briefing from the

1 The Court refers to Karen Frohn as Plaintiff Frohn and Greg Frohn as Mr. Frohn. parties, the question of a permanent seal as to portions of the Opinion is now before the Court. For the reasons discussed more fully below, the Court concludes that sealing is inappropriate.

True, the Court previously allowed the parties to file the medical information at issue under seal when they used it to support their briefing on summary judgment. (Docs. 59, 72). At that time, the Court found the public’s right of access, as outlined in Shane Grp., Inc. v. Blue Cross Blue Shield of Mich., 825 F.3d 299 (6th Cir. 2016), did not require these documents to be filed publicly. But now the Court has relied on that information as a basis for its dispositive ruling. That changes the analysis. The public right of access to judicial proceedings and materials is secured both

by the First Amendment and the common law. See Nixon v. Warner Commc’ns, Inc., 435 U.S. 589 (1978). One aspect of that access right is that the public has a presumptive right to attend and watch civil trials. Brown & Williamson, 710 F.2d 1165, 1178–79 (6th Cir. 1983). Here, by granting summary judgment, the Court resolved the parties’ dispute on the papers—with the Court’s decision standing in lieu of a trial on the merits. As a result, the Court affords its dispositive Opinion the same

presumptive openness that would attach to any civil trial in its courtroom. See Tri- County Wholesale Distribs., Inc. v. Wine Grp., Inc., 565 F. App’x 477, 490 (6th Cir. 2012) (Gwin, J, concurring in part and dissenting in part) (“The public holds a qualified constitutional right of access to … judicial opinions.”). In essence, the Court must determine whether, had this matter proceeded to trial, the Court would have sealed the courtroom when the parties presented the evidence Plaintiff Frohn now seeks to redact. To obtain redaction against that backdrop, Plaintiff Frohn must overcome a

“strong presumption in favor of openness.” Brown & Williamson, 710 F.2d at 1179. That is no easy task. In evaluating her request, the Court considers “why the interests in support of nondisclosure are compelling, why the interests supporting access are less so, and why the seal itself is no broader than necessary.” Shane Grp., 825 F.3d at 306 (citing Brown & Williamson, 710 F.2d at 1176). The Sixth Circuit has repeatedly cautioned that “only the most compelling reasons can justify non- disclosure of judicial records.” In re Nat’l Prescription Opiate Litig., 927 F.3d 919, 940

(6th Cir. 2019) (brackets and citation omitted). Start with Plaintiff Frohn’s and Mr. Frohn’s interests supporting nondisclosure. As the Court recognized, although Mr. Frohn is now deceased, he has a continuing interest in the confidentiality of his medical information under Ohio Revised Code § 2317.02. (Doc. 41, #621; Doc. 72, #4916). And Plaintiff Frohn, as his surviving spouse, asserts her interest in maintaining the confidentiality of her late

husband’s medical information. (Doc. 86, #6383). For two reasons, though, these interests are now diminished compared to when Plaintiff Frohn first filed under seal. First, the Court has now issued an Opinion holding that Plaintiff Frohn validly waived Mr. Frohn’s privacy interest under § 2317.02. And in that waiver, Plaintiff Frohn gave Globe Life permission to use Mr. Frohn’s information for “legally permissible activities” related to his policy. (Doc. 30- 1, #467). Here, Globe Life did that in defending itself in this lawsuit.2 Second, the Court’s Opinion disposes of proceedings Plaintiff Frohn herself

initiated. In filing suit, she had notice that she may need to disclose, in a public forum, the facts necessary for the Court to resolve her lawsuit. True, under her theory of the case, Mr. Frohn’s medical information lacked relevance because Globe Life breached its contract by demanding that information in the first instance. But she should have known that Globe Life would argue otherwise and that it may assert a defense under Ohio Revised Code § 3911.06. And that defense, as discussed below, made Mr. Frohn’s medical conditions relevant. She has little basis for crying foul over the Court

disclosing information Globe Life successfully used to defend the case she started. See Mitze v. Saul, 968 F.3d 689, 692–93 (7th Cir. 2020) (recognizing that a suit over a denial of disability payments necessarily requires a plaintiff make public otherwise confidential medical information); Tyson v. Regency Nursing, LLC, No. 3:17-cv-91, 2018 WL 632063, at *1 (W.D. Ky Jan. 30, 2018) (finding plaintiff lost applicable privileges to the confidentiality of medical information when putting them in

controversy); see also In re Chiquita Brands Int’l, Inc., 965 F.3d 1238, 1242 (11th Cir. 2020) (“A lawsuit is a public event. Parties who ask a court to resolve a dispute must typically walk in the public eye.”). Moreover, the Court’s Opinion does not disclose

2 To the extent Health Insurance Portability and Accountability Act also once protected Mr. Frohn’s medical information, Plaintiff Frohn’s waiver also expressly waived that privilege. (Doc. 30-1, #467). the medical records themselves, but only the particular information from those records on which the Court relied to arrive at its decision. Of course, Frohn maintains that she did not waive Mr. Frohn’s privilege and

that the Court erred in holding otherwise. Thus, she believes that she and Mr. Frohn still retain a compelling interest in keeping his medical information confidential. Fair enough. But this Court has already decided that issue contrary to her position. If she disagrees, which is her right, that is a matter for the Sixth Circuit Court of Appeals. But, under the Court’s Opinion as it stands, the privacy interests are now diminished. On the other side stands the public’s interest in disclosure. And here, the public has a formidable (and constitutionally protected) interest in accessing, reading, and

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Nixon v. Warner Communications, Inc.
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493 F. Supp. 2d 1035 (S.D. Ohio, 2007)
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