Savel v. MetroHealth System

District Court, N.D. Ohio·Decided July 26, 2024·No. 1:22-cv-02154·Unknown

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO

: FRANK SAVEL, et al., : CASE NO. 1:22-cv-02154 : Plaintiffs, : ORDER : [Resolving Doc. 46] v. : : METROHEALTH SYSTEM, : : Defendant. : :

JAMES S. GWIN, UNITED STATES DISTRICT COURT JUDGE:

Plaintiff Frank Savel moves under Federal Rule of Civil Procedure 45(d)(3)(A)(iii)1 to quash subpoenas issued by Defendant The MetroHealth System (MetroHealth) to former Plaintiffs Isaac Allison, Darlene Rutledge, and Kerry Stouges.2 Defendant MetroHealth opposes. For the following reasons, the Court DENIES Plaintiff Savel’s motion to quash Defendant MetroHealth’s subpoena of former Plaintiffs Allison, Rutledge, and Stouges. I. BACKGROUND At Plaintiff Savel’s May 29, 2024 deposition, Savel testified that he learned of a potential lawsuit against MetroHealth through membership in a Telegram Messenger (Telegram) group message with other MetroHealth employees.3 Afterwards, Defendant MetroHealth sought production of the Telegram group message as a document responsive

1 Fed. R. Civ. P. 45(d)(3)(A)(iii). 2 Doc. 46. Previously, the Court granted Defendant MetroHealth’s motion to dismiss Plaintiffs Isaac Allison, Darlene Rutledge, and Kerry Stouges, and other named Plaintiffs. Doc. 23. The Sixth Circuit upheld the Court’s dismissal of all Plaintiffs save Plaintiff Savel and former Plaintiff Crockett. , 96 F.4th 932, 944-45 (6th Cir. 2024). 3 Doc. 48-1, PageID #: 1203-1204. Telegram is a “cloud-based, cross-platform, online instant messaging application that allows users to exchange messages, share media and files, and hold private and group voice or video calls.” Doc. 46, to its discovery requests.4 After several follow-ups with Plaintiff Savel’s counsel, Defendant MetroHealth issued records subpoenas to individuals that Savel mentioned that he communicated with via Telegram.5

With their subpoenas, Defendant MetroHealth seek all Telegram communications “related to MetroHealth’s COVID-19 vaccination program and/or exemption requests related to the same,” and “[a]ny communications you had with Frank Savel and/or Danielle Crockett regarding MetroHealth’s COVID-19 vaccination program and/or exemption requests related to the same.”6 Plaintiff Savel moves to quash Defendant MetroHealth’s subpoenas. He argues that

the contents of a specific Telegram message group are shielded from production by the common interest exception to the third-party disclosure rule.7 This private, invitation-only Telegram group was created by MetroHealth employees to discuss legal options regarding MetroHealth’s vaccine mandates. Savel says that “[a]t all times, the participants in the Telegram group shared a common legal interest pertaining to the mandates and the proper responses thereto.”8 Defendant MetroHealth opposes the motion to quash.9

On July 11, 2024, the Court conducted a status conference, where it discussed the subpoena of the Telegram group. It ordered Plaintiff Savel to file the Telegram communications under seal for in camera review.10

4 Doc. 48-3, PageID #: 1217-18. 5 Docs. 48-4, 48-5, 48-6. 6 Doc. 46, PageID #: 1163. 7 at PageID #: 1164. 8 9 Doc 48. Now having carefully reviewed the Telegram messages, the Court proceeds to a discussion of Plaintiff Savel’s motion to quash. II. LEGAL STANDARD

Rule 26 provides that parties may obtain discovery regarding, “any nonprivileged matter that is relevant to any party’s claim or defense and proportional to the needs of the case.”11 While relevancy is broad, “district courts have discretion to limit the scope of discovery [when] the information sought is overly broad or would prove unduly burdensome to produce.”12 Rule 45 permits a party to issue a subpoena commanding a non-party to produce documents.13 A district court must quash a subpoena that “requires disclosure of privilege

or other protected matter[s] . . . or subjects a person to undue burden.”14 The movant seeking to quash the subpoena bears the burden of persuasion.15 Plaintiff Savel argues that his motion to quash should be granted because the subpoena seeks communications that falls within the common interest exception to waiver of attorney-client privilege due to third-party disclosure.16 Under the attorney-client privilege, “(1) [w]here legal advice of any kind is sought (2)

from a professional legal adviser in his capacity as such, (3) the communications relating to that purpose, (4) made in confidence (5) by the client, (6) are at his instance permanently protected (7) from disclosure by himself or the legal adviser, (8) unless the protection is

11 Fed. R. Civ. P. 26(b)(1). 12 , 474 F.3d 288, 305 (6th Cir. 2007) (citing Fed. R. Civ. P. 26(b)(2)). 13 Fed. R. Civ. P. 45(a)(1)(D). 14 Fed. R. Civ. P. 45(d)(3)(A)(iii)-(iv). 15 , 335 F.R.D. 115, 119 (N.D. Ohio 2020) (citing , No. 1:18-cv-507, 2019 WL 109368, *2 (N.D. Ohio. Jan. 4, 2019)). waived.”17 “Voluntary disclosure of communications made with one’s attorney to a third party generally waives the attorney-client privilege.”18 Courts have held that a client waives attorney-client privilege when the client communicates in circumstances where the client

could not reasonably believe the communications were confidential.19 The common interest doctrine is an exception to this general rule that voluntary disclosure of communications made with one’s attorney to a third party waives the attorney- client privilege. The common interest doctrine expands coverage of the attorney-client privilege “to include situations in which two or more clients with a common interest in a matter agree to exchange information regarding the matter.”20

The parties must “have the same goal in litigation,” but they need not be parties to the same litigation.21 “Additionally, it is not necessary that parties be in agreement on every point; a communication is privileged so long as it does it deals with a matter on which parties have agreed to work toward a mutually beneficial goal, even if parties are in conflict on some points.”22 “Thus, the common interest doctrine protects documents and communications from discovery if two conditions are satisfied: (1) the documents or communications were shared

17 , 134 F.3d 351, 355 (6th Cir. 1998) (citing , 965 F.2d 126, 129 (6th Cir. 1992)). The parties have not briefed whether state or federal privilege law applies under Rule 501 in a case involving state and federal claims. However, “[t]here is no material difference between Ohio’s attorney-client privilege and the federal attorney-client privilege.” , No. 2:17-cv-708, 2021 WL 4891307, at *7 (S.D. Ohio Oct. 20, 2021) (citing , 980 N.E.2d 1072, 1079-80 (Ohio Ct. App. 2012)). And both Ohio and federal law recognize the common interest and joint representation doctrines. , 2021 WL 4891307, at *7-8. The doctrines’ boundaries may vary slightly under Ohio versus federal law. (Ohio common interest recognizes a “common legal strategy” whereas federal common interest doctrine requires “identical legal interest”).

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Savel v. MetroHealth System, (N.D. Ohio 2024).

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