Loparo v. Univ. Hosps. Health Sys., Inc.

2024 Ohio 663, 236 N.E.3d 917
CourtOhio Court of Appeals
DecidedFebruary 22, 2024
Docket112765
StatusPublished
Cited by4 cases

This text of 2024 Ohio 663 (Loparo v. Univ. Hosps. Health Sys., Inc.) 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
Loparo v. Univ. Hosps. Health Sys., Inc., 2024 Ohio 663, 236 N.E.3d 917 (Ohio Ct. App. 2024).

Opinion

[Cite as Loparo v. Univ. Hosps. Health Sys., Inc., 2024-Ohio-663.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

TERRY LOPARO, :

Plaintiff-Appellee, : No. 112765 v. :

UNIVERSITY HOSPITALS HEALTH : SYSTEM, INC., ET AL.,

Defendants-Appellants. :

JOURNAL ENTRY AND OPINION

JUDGMENT: AFFIRMED IN PART, REVERSED IN PART, AND REMANDED RELEASED AND JOURNALIZED: February 22, 2024

Civil Appeal from the Cuyahoga County Court of Common Pleas Case No. CV-22-961541

Appearances:

Gioffre, Schroeder & Jansky Co., LPA, and Michael S. Schroeder, and David J. Jansky, for appellee.

Hanna, Campbell & Powell, LLP, and Gregory T. Rossi, and Rocco D. Potenza, for appellants.

EMANUELLA D. GROVES, J.:

Defendants-appellants, University Hospitals Health System, Inc., and

University Hospitals Lake West Medical Center (“Appellants”), appeal the trial

court’s judgment ordering them to produce interrogatory responses to plaintiff- appellee Terry Loparo (“Appellee”). For the reasons that follow, we affirm in part

and reverse in part and remand the judgment of the trial court.

Procedural History and Factual Background

Appellee initiated this wrongful death action against Appellants arising

from the death of Phillip Loparo (“Loparo”) on October 1, 2021. Loparo arrived at

the University Hospitals Lake West Medical Center’s emergency department on

September 28, 2021, complaining of shortness of breath. Loparo was administered

two COVID-19 tests, which were both negative. After waiting more than five hours

to be treated, Loparo suffered respiratory arrest and subsequently died. Appellee’s

wrongful death and negligence claims are based on Appellants’ alleged failure to

treat Loparo timely. Appellants responded to the complaint with a motion for

judgment on the pleadings, raising an affirmative immunity defense under H.B.

606.

In their motion for judgment on the pleadings, Appellants argued that

immunity was proper because patients with more severe COVID-19 symptoms

needed to be seen before Loparo. (See University Hospitals, et al., Appellants’

motion for judgment on the pleadings ¶ 9, October 31, 2022). The trial court denied

the motion.

Appellee propounded discovery, including interrogatories upon

Appellants. These interrogatories requested information for every patient in the

emergency department at University Hospitals Lake West Medical Center from 8:00

p.m., on September 28, 2021, through 2:00 a.m., on September 29, 2021. Interrogatory 22 requested information from the registration forms for each

patient’s age, sex, race, reason for visit/chief complaint, encounter start date and

time, and encounter stop date and time. Interrogatory 23 requested information

from the tracking board visit form for their arrival date and time, discharge date and

time, patient complaint, treating complaint, disposition diagnosis, disposition, and

dispositioning provider. Interrogatory 24 requested the patient’s triage start time,

triage end time, person who performed triage, and triage level.

Appellants objected to interrogatories 22, 23, and 24. Their response

to each of these interrogatories was:

Objection: This Interrogatory is vague, ambiguous, and unclear. It is also overly broad, unduly burdensome and is not proportional to the needs of the case. The Interrogatory seeks information that is not relevant and not reasonably calculated to lead to the discovery of admissible evidence. It also seeks information that is protected by HIPAA and the physician-patient privilege.

Due to Appellants’ response, Appellee filed a motion to compel

responses to discovery. The trial court ordered Appellants to produce responses to

the interrogatories under seal for the court to conduct an in camera inspection of the

records. On April 20, 2023, Appellants produced three spreadsheets related to

Appellee’s interrogatory Nos. 22, 23, and 24 for the court’s in camera review. In

their notice of submission of documents for in camera inspection, Appellants noted

they were not waiving any objections to producing the personal health information

of nonparty patients, which was protected by the physician-patient privilege and

HIPAA. Appellants also produced the affidavit of Suzanne Clemente (“Clemente”), which stated that 65 other patients were in the emergency department during the

relevant time. Clemente also stated:

“No document existed within UH Lake West that listed this data in its entirety as requested by Plaintiff;” in order to provide the responses to these Interrogatories, it was necessary for me to access the protected health information/medical charts of the patients who were present in the ED during this timeframe” and “I manually entered the data into the spreadsheet.”

(Quoting Clemente Affidavit at ¶ 4-7.)

The trial court granted Appellee’s motion to compel discovery on April

23, 2023. The court stated in its journal entry:

Upon a review of the answers, the claim of privilege is overruled, primarily because the information is not traceable to any particular patient other than the plaintiff’s decedent, where applicable.

(J.E. Apr. 23, 2023.)

Appellants appeal, raising one assignment of error for review.

Assignment of Error

The trial court erred in granting the plaintiff’s motion to compel the defendants to produce personal medical information of nonparty patients as this order violates R.C. 2317.02(B)(1), Ohio’s physician- patient privilege.

Standard of Review

The party seeking to exclude evidence as privileged bears the burden of

establishing that requested information is protected from disclosure. Pietrangelo v.

Hudson, 2019-Ohio-1988, 136 N.E.3d 867, ¶ 15 (8th Dist.). A discovery dispute is

generally reviewed for abuse of discretion; however, whether the information sought

in discovery is a confidential communication and privileged is a question of law that is reviewed de novo. Id. See also Hance v. Cleveland Clinic, 2021-Ohio-1493, 172

N.E.3d 478, ¶ 25 (8th Dist.). When the trial court’s order concerning privileged

information would result in the disclosure of the disputed discovery, it is treated as

a final appealable order. Humphry v. Riverside Methodist Hosp., 22 Ohio St.3d 94,

97, 488 N.E.2d 877 (1986); Grove v. Northeast Ohio Nephrology Assocs., 164 Ohio

App.3d 829, 2005-Ohio-6914, 844 N.E.2d 400, ¶ 9 (9th Dist.); Burnham v.

Cleveland Clinic, 151 Ohio St.3d 356, 2016-Ohio-8000, 89 N.E.3d 536, ¶ 24.

Law and Analysis

Appellants argue that the requested information is exempt from

disclosure as privileged physician-patient records under R.C. 2317.02(B).

Moreover, Appellants contend the trial court’s decision is inconsistent with the Ohio

Supreme Court’s interpretation of R.C. 2317.02 in Roe v. Planned Parenthood

Southwest Ohio Region, 122 Ohio St.3d 399, 2009-Ohio-2973, 912 N.E.2d 61, and

the provisions of the Health Insurance Portability and Accountability Act

(“HIPAA”). Appellants assert that their interrogatory responses required the

production of nonparty privileged patient communications and medical records.

Further, Appellants’ immunity claim is based on the number of

nonparty COVID-19 patients treated in the emergency department with more severe

symptoms than Loparo.

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Bluebook (online)
2024 Ohio 663, 236 N.E.3d 917, Counsel Stack Legal Research, https://law.counselstack.com/opinion/loparo-v-univ-hosps-health-sys-inc-ohioctapp-2024.