Simon v. Specialty Orthopaedics, P.C.

48 Pa. D. & C.5th 397
CourtPennsylvania Court of Common Pleas, Mercer County
DecidedMay 22, 2015
DocketNo. 2013-3056
StatusPublished

This text of 48 Pa. D. & C.5th 397 (Simon v. Specialty Orthopaedics, P.C.) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Mercer County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Simon v. Specialty Orthopaedics, P.C., 48 Pa. D. & C.5th 397 (Pa. Super. Ct. 2015).

Opinion

WALLACE, /.,

Presently before the Court is Plaintiff Mary Jane Simon’s Motion to Compel Defendant’s Discovery Responses.

Facts

Mary Jane Simon (Plaintiff) is an adult individual residing in Sharon, PA. Specialty Orthopaedics, P.C. (Defendant) is a corporation conducting business in Pennsylvania with a registered office in Hermitage, PA. On October 3, 2011, Plaintiff attended a therapy/exercise session with Defendant. She was being instructed by an employee, Robert Griffith. Mr. Griffith instructed Plaintiff to balance her leg on a large fitness ball. Plaintiff was 82 years old at the time and had only attended two prior [400]*400sessions with Defendant. While attempting to comply with Mr. Griffith’s instructions, Plaintiff fell into gym equipment located next to her. Plaintiff alleges that she sustained injuries as a result of the fall accident and has suffered numerous complications

On January 23, 2014, Plaintiff served upon Defendant Plaintiff’s First Set of Interrogatories and Requests for Production of Documents Directed to Defendant requesting the identities of any eye witnesses to the accident. Plaintiff filed a Motion to Compel Discovery Responses on March 10, 2014, and said motion was granted on March 17,2014. Defendant served its Answers to Plaintiff’s First Set of Interrogatories and Requests for Production of Documents upon Plaintiff’s counsel on April 7, 2014. In its Answers, Defendant objected to providing the identities of any witnesses to the accident on the grounds that their identities are protected by the federal Health Insurance Portability and Accountability Act of 1996 (HIPAA). Plaintiff filed another Motion to Compel Discovery Responses on August 1, 2014 alleging that Defendant’s discovery responses were deficient. On August 4, 2014, this Court issued an Order reserving any ruling on the HIPAA issue pending Defendant’s briefing of said issue. Defendant was given seven days to submit a brief with respect to the HIPAA issue, and Plaintiff was given 10 days to file a reply brief.

However, Defendant did not brief the HIPAA issue. Instead, Defendant sent correspondence to Plaintiff’s counsel on August 8, 2014 amending its response to Interrogatory 20, claiming that Defendant was unaware of whether any other individuals present at the Wellness Center were eyewitnesses to the incident. On August 18, 2014, Plaintiff sent her Third Set of Interrogatories [401]*401and Second Request for Production of Documents to Defendant limited to the issue of identifying potential witnesses. Defendant objected to this discovery request on the grounds that the identities of the individuals at the Wellness Center are protected under HIPAA. Plaintiff then filed another Motion to Compel Discovery Responses on November 19, 2014. Defendant then filed an Omnibus Brief addressing the HIPAA issue. There was a hearing before this Court on December 22, 2014. In an Order issued on the same day, this Court noted that Defendant submitted a brief on the HIPAA issue concerning the identity of witnesses. This Court gave Plaintiff 30 days to submit her reply brief, and the parties were to notify the Court whether they wished to schedule argument in this matter. On February 2, 2015, Defendant filed a Praecipe for Argument Date to resolve the HIPAA dispute. Oral argument was held before this Court on April 6, 2015.

Law and Discussion

At issue in this case is whether the identities of potential eye witnesses to Plaintiff’s accident in Defendant’s Wellness Center is protected healthcare information under HIPAA. This Court will discuss the following issues: whether HIPAA creates an evidentiary privilege injudicial proceedings, whether Defendant is a healthcare provider under HIPAA and whether the information sought is protected health information under HIPAA? For the reasons discussed below, this Court finds that the identity of a potential witness is not protected under the HIPAA privacy provisions.1

[402]*402Whether HIPAA may be used as an Evidentiary Privilege?

First, this Court will examine whether the HIPAA privacy provisions create an evidentiary privilege in judicial proceedings. In T.M. v. Elwyn, Inc., 950 A.2d 1050 (Pa.Super. 2008), the plaintiff was a student at Elwyn Alternative School, which handled and educated children with mental health and behavioral issues. The plaintiff sued the school for a number of claims including negligent hiring, training and supervision after being assaulted on multiple occasions by one of the defendant’s employees. The plaintiff made several discovery requests, which the trial court granted. These discovery requests involved obtaining pleadings and discovery from other lawsuits against the school for sexual abuse by its employees. The defendant appealed raising a number of objections based on privilege. One of these obj ections was that the requested information was protected by HIPAA. The defendant argued that it was a covered entity under HIPAA and that it must comply with HIPAA and its associated regulations because it provides behavioral and mental health services. The Superior Court disagreed with the defendant and found that HIPAA does not create an evidentiary privilege in court proceedings. Id. at 1059-60. Additionally, the Superior Court noted that even if the defendant was a protected entity under HIPAA, section 164.512(e) of the privacy rule “indicates generally (with certain caveats and requirements for disclosure pursuant to a court order or [403]*403subpoena) that release of protected health information is permissible without patient authorization in judicial proceedings.” Id. 1060. (citing 45 C.F.R. § 164.512(e)). Thus, even protected health information may be obtained injudicial proceedings.

HIPAA outlines the steps to follow in order to obtain protected health information during a judicial proceeding in 45 CFR 164.512(e). There are three ways to obtain protected health information in judicial proceedings under HIPAA. First, a party may obtain a Court Order to acquire such information. 45 CFR 164.512(e)(l)(i). In the absence of a Court Order, 45 CFR 164.512(e)(1) (ii)(A) and (B) provide two additional methods available when used in conjunction with more traditional means of discovery. Specifically relevant to this case, § 164.512(e) permits disclosure of protected health information in the course of any judicial proceeding “[i]n response to an order of a court or administrative tribunal, provided that the covered entity discloses only the protected health information expressly authorized by such order . . .” 45 C.F.R. § 164.512(e)(l)(i). Therefore, Defendant cannot use HIPAA as a shield to avoid reasonable discovery requests injudicial proceedings.

Whether Defendant is a Healthcare Provider under HIPAA?

Next, this Court must determine whether Defendant is an entity covered by HIPAA’s privacy provisions.

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Related

T.M. v. Elwyn, Inc.
950 A.2d 1050 (Superior Court of Pennsylvania, 2008)
Scopel v. Donegal Mutual Insurance
698 A.2d 602 (Superior Court of Pennsylvania, 1997)
Erie Indemnity Co. v. Coal Operators Casualty Co.
272 A.2d 465 (Supreme Court of Pennsylvania, 1971)
Leonhard Estate
56 Pa. D. & C.2d 185 (Lebanon County Court of Common Pleas, 1972)

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Bluebook (online)
48 Pa. D. & C.5th 397, Counsel Stack Legal Research, https://law.counselstack.com/opinion/simon-v-specialty-orthopaedics-pc-pactcomplmercer-2015.