Ohio Bur. of Workers' Comp. v. Salkin

2011 Ohio 4260
CourtOhio Court of Appeals
DecidedAugust 25, 2011
Docket96173
StatusPublished
Cited by3 cases

This text of 2011 Ohio 4260 (Ohio Bur. of Workers' Comp. v. Salkin) 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
Ohio Bur. of Workers' Comp. v. Salkin, 2011 Ohio 4260 (Ohio Ct. App. 2011).

Opinion

[Cite as Ohio Bur. of Workers' Comp. v. Salkin, 2011-Ohio-4260.]

Court of Appeals of Ohio EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

JOURNAL ENTRY AND OPINION No. 96173

OHIO BUREAU OF WORKERS’ COMPENSATION

PLAINTIFF-APPELLEE

vs.

BRETT SALKIN, ET AL. DEFENDANTS-APPELLANTS

JUDGMENT: AFFIRMED IN PART, REVERSED IN PART, AND REMANDED

Civil Appeal from the Cuyahoga County Common Pleas Court Case No. CV-728169

BEFORE: E. Gallagher, J., Boyle, P.J., and S. Gallagher, J. 2

RELEASED AND JOURNALIZED: August 25, 2011

ATTORNEYS FOR APPELLANTS

Larry W. Zukerman S. Michael Lear Brian A. Murray Zukerman, Daiker & Lear Co., LPA 3912 Prospect Avenue Cleveland, Ohio 44115

ATTORNEYS FOR APPELLEE

Mike DeWine Ohio Attorney General

By: Patsy A. Thomas Assistant Attorney General 150 E. Gay Street, 22nd Floor Columbus, Ohio 43215

James A. Barnes Assistant Attorney General 140 East Town Street 9th Floor Columbus, Ohio 43215-6001

EILEEN A. GALLAGHER, J.:

{¶ 1} Brett Salkin (“Salkin”) appeals the decision of the trial court

finding him in contempt of court and ordering him to comply with a

November 24, 2008 subpoena issued by the Bureau of Workers’ Compensation 3

(“BWC”). Salkin argues the trial court erred in ordering him to comply with

the subpoena because it was not validly issued, that the Fifth Amendment’s

protections against self-incrimination, and the Health Insurance Portability

and Accountability Act (“HIPAA”) protect him from releasing the requested

information, and that the court erred in finding him in contempt. For the

following reasons, we affirm in part, and reverse in part.

{¶ 2} Salkin is a certified health partnership provider for the Ohio

BWC and provides counseling services to injured workers. The BWC is a

state agency responsible for the administration and maintenance of the

workers’ compensation fund. It is empowered by R.C. 4121.15 and 4123.08

to conduct investigations, and among other powers, to issue subpoenas in

conjunction with those investigations. Additionally, R.C. 4121.121and Ohio

Adm.Code 4123-6-45 furnish the BWC with the duty of reviewing and

auditing a provider’s patient and billing records as part of its responsibility

for the management of the bureau. Further, all certified health partnership

providers sign the BWC’s Health Partnership Provider Application and

Agreement, which states as follows:

“PROVIDER agrees to create, maintain, and retain sufficient records, papers, books, and documents in such form to fully substantiate the delivery, value, necessity, and appropriateness of goods and services provided to injured workers under the Health Partnership Plan (HPP) or of significant business transactions, as provided by OAC 4123-6-451. PROVIDER further agrees to make such records available for review by BWC * * * within 30 calendar days or such time agreed to by the 4

parties, in accordance with OAC 4123-6-45.”

{¶ 3} On November 24, 2008, BWC Special Agent Jennifer Murphy

served a subpoena on Salkin requesting documentation of services rendered

including, but not limited to: treatment notes, sign-in sheets, and patient

encounter forms for eleven injured workers serviced between December 1,

2006 thru June 1, 2008. The subpoena ordered Salkin to provide the

requested documents by December 8, 2008. At the request of Salkin’s

counsel, he was afforded several extensions of time; however, he never did

provide the documents to the BWC.

{¶ 4} On June 1, 2010, pursuant to the statutory authority outlined in

R.C. 4121.15, the BWC filed an application to enforce the subpoena in the

Cuyahoga County Court of Common Pleas. The trial court scheduled a

hearing for December 8, 2010. On the day of the hearing, Salkin failed to

appear. The court conducted the hearing in his absence and at the

conclusion, ruled from the bench. The trial court found the BWC’s

application to enforce the subpoena to be well taken and granted the BWC’s

motion. The trial court also found Salkin in contempt of court for failing to

respond to a properly issued subpoena and fined him $250. The court

ordered Salkin to provide the BWC with the requested documents on or

before December 15, 2010.

{¶ 5} Salkin appeals, raising the seven assignments of error contained 5

in the appendix to this opinion.

{¶ 6} Generally, an appellate court applies an abuse of discretion

standard when reviewing a trial court’s decision to enforce or quash an

administrative subpoena. Petro v. N. Coast Villas Ltd. (2000), 136 Ohio

App.3d 93, 735 N.E.2d 985. Nevertheless, when a trial court’s discretionary

decision is based on a specific construction of law, that decision should not be

afforded the deference that is usually due to the trial court. Id. It is only

when a trial court’s decision is based on a specific construction of law that an

appellate court reviews the decision under a de novo standard. Id.

{¶ 7} It is with this standard in mind that we review Salkin’s seven

assignments of error.

{¶ 8} In his first assignment of error, Salkin argues the trial court

erred in determining that the BWC’s November 24, 2008 subpoena was

validly issued. We find no merit to this argument.

{¶ 9} The Ohio Supreme Court has held that under Ohio

administrative law, a subpoena will be judicially enforced only so long as: (1)

the inquiry is permitted by law, (2) the records sought are relevant to the

matter in issue, and (3) the records’ disclosure will not cause unreasonable

costs and difficulty. State ex rel. Civ. Rights Comm. v. Gunn (1976), 45 Ohio

St.2d 262, 344 N.E.2d 327; Petro.

{¶ 10} As outlined above, the BWC is a state agency responsible for the 6

administration and maintenance of the workers’ compensation fund. It is

empowered by R.C. 4121.15 and 4123.08 to conduct investigations, and

among other powers, to issue subpoenas in conjunction with those

investigations. Additionally, R.C. 4121.121 and Ohio Admin.Code 4123-6-45

furnish the BWC with the responsibility for reviewing and auditing a

provider’s patient and billing records as part of its responsibility for the

management of the bureau. Accordingly, Ohio law permits the BWC to

subpoena its patient providers.

{¶ 11} We next determine whether the documents sought under the

BWC’s November 24, 2008 subpoena are relevant to the matter in issue, and

would not cause Salkin unreasonable costs and difficulty. While Salkin

argues the BWC’s failure to establish a causal link between Murphy’s

investigation and the records requested, it is not the BWC’s burden to prove

the relevancy and reasonableness of subpoenas it issues; the burden rests

with Salkin. It is clear that when the Ohio Civil Rules of Procedure do not

apply, the burden of proof rests with the party challenging the subpoena.

Davies v. Columbia Gas & Elec. Co. (1938), 68 N.E.2d 571, 578; Petro. Thus,

it is incumbent on this Court to determine whether Salkin met his burden as

to irrelevancy and unreasonable costs and difficulty.

{¶ 12} In the instant matter, the BWC seeks Salkin’s documentation of

services rendered including, but not limited to treatment notes, sign-in 7

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2011 Ohio 4260, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ohio-bur-of-workers-comp-v-salkin-ohioctapp-2011.