in Re: LaSethia G. Whiteley

CourtCourt of Appeals of Texas
DecidedJune 13, 2002
Docket13-02-00236-CV
StatusPublished

This text of in Re: LaSethia G. Whiteley (in Re: LaSethia G. Whiteley) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
in Re: LaSethia G. Whiteley, (Tex. Ct. App. 2002).

Opinion

                                   NUMBER 13-02-236-CV

                             COURT OF APPEALS

                   THIRTEENTH DISTRICT OF TEXAS

                                CORPUS CHRISTI

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                              IN RE: LaSETHIA G. WHITELEY

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                            On Petition for Writ of Mandamus.

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                                   O P I N I O N

        Before Chief Justice Valdez and Justices Dorsey and Rodriguez

                                Opinion by Justice Rodriguez

In this original proceeding, relator, LaSethia G. Whiteley, seeks mandamus relief from an order issued by respondent, the Honorable Robert C. Cheshire, of the 377th District Court of Victoria County, denying Whiteley=s motion to compel discovery of non-party medical records by real party in interest, John C. Wright, M.D.  We conclude respondent abused his discretion, and conditionally grant the petition for writ of mandamus.


                                                    I.  Background

The underlying action is for medical malpractice.  Dr. Wright, a physician and defendant in this lawsuit, performed a total knee replacement on Whiteley.  During the surgery, Dr. Wright used the Cave-Rowe technique to resurface the kneecap.[1]  Whiteley sued Dr. Wright claiming the total knee replacement failed.  Whiteley=s motion to compel production of records of  non-party medical records of patients on whom Dr. Wright performed the Cave-Rowe procedure was denied.[2]  The trial court also denied her motion on rehearing.  Whiteley seeks mandamus relief from this discovery ruling.

II.  Standard of Review

Mandamus is an extraordinary writ and should issue only to correct an abuse of discretion.  Walker v. Packer, 827 S.W.2d 833, 842 (Tex. 1992) (orig. proceeding).  The trial court has no discretion to misinterpret or misapply the law.  Id. at 840.  A clear abuse of discretion occurs when the trial court clearly fails to analyze or apply the law correctly.  Id.  Mandamus will not issue when there is an adequate remedy by appeal.  Id.


III.  Abuse of Discretion

Whiteley contends the trial court abused its discretion when it failed to apply an exception to the physician-patient privilege.

A.  Exception to Physician-Patient Privilege

Texas Rule of Evidence 509 provides that A[c]onfidential communications between a physician and a patient, relative to or in connection with any professional services rendered by a physician to the patient are privileged and may not be disclosed.@  Tex. R. Evid. 509(c)(1).  However, an exception to the physician-privilege applies (1) when the condition is relied upon as part of a party=s claim or defense, meaning that the condition itself is a fact that carries some legal significance, and (2) when the records sought to be discovered are relevant to the condition at issue.  Id. at 509(e)(4); R.K. v. Ramirez, 887 S.W.2d 836, 843 (Tex. 1994) (orig. proceeding).  The privilege is terminated when any party relies on the condition of the patient as part of his claim or defense, Aeven though the patient has not personally placed the condition at issue, and even though the patient is not a party to the litigation.@  Id. at 842; see Bristol-Myers Squibb Co. v. Hancock, 921 S.W.2d 917, 921 (Tex. App.BHouston [14th Dist.] 1996, orig. proceeding).

1.  Condition Relied on as Defense


In assessing the application of the exception to the physician-patient privilege, we must first determine whether the condition of Dr. Wright=s patients is part of a claim or defense in this case.  R.K., 887 S.W.2d at 843.  This determination should be made on the face of pleadings, without reference to evidence that is allegedly privileged.  Id. at 843 n.7; Bristol-Myers Squibb Co., 921 S.W.2d at 921. 

In her original petition, Whiteley asserted Dr. Wright failed to properly perform medical treatment necessary according to the standards set by the medical profession.  Whiteley claimed this alleged breach of duty proximately caused her damages.  In his second amended answer, as one of his defenses, Dr. Wright asserted he A

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