Slayton v. Biebel

37 Pa. D. & C.4th 140, 1998 Pa. Dist. & Cnty. Dec. LEXIS 145
CourtPennsylvania Court of Common Pleas, Crawford County
DecidedJune 4, 1998
Docketno. 1993-127
StatusPublished
Cited by1 cases

This text of 37 Pa. D. & C.4th 140 (Slayton v. Biebel) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Crawford County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Slayton v. Biebel, 37 Pa. D. & C.4th 140, 1998 Pa. Dist. & Cnty. Dec. LEXIS 145 (Pa. Super. Ct. 1998).

Opinion

VARDARO, J.,

The present action arises from an automobile accident occurring on August 8, 1991 and in various phases of discovery since its initiation in 1993. At this point, the defendant-Biebel has served subpoenas upon various non-party health care providers and custodians of workers’ compensation records in accord with Pa.R.C.P. 4009.21(a). The plaintiff has invoked his rights under Pa.R.C.P. 4009.21(b) and has given notice of his objection to the issuance of these subpoenas. The cornerstone of plaintiff’s objection is that, contained in the information which is sought, are medical matters of a private and personal [142]*142nature and medical matters which are irrelevant to this cause of action. Plaintiff requests that the records defendant seeks be first sent to plaintiff’s counsel such that matters which are irrelevant and undiscoverable may be extracted. The defendant opposes such a procedure.

DISCUSSION

The limits of the scope of discovery are set forth in Pa.R.C.P 4003.1(a) which provides in material part that “a party may obtain discovery regarding any matter not privileged, which is relevant to the subject matter involved in the pending action . . . .” The scope of discovery is necessarily broad by definition and everything is presumed to be discoverable unless subject to a proscription set forth in the rules. Mountain View Condominium Owners’ Ass’n v. Mountain View Associates, 9 D.&C.4th 81 (1991). A party then may “obtain discovery of any matter, not privileged, which is relevant to the subject matter involved in the pending action ... if the information sought appears reasonably calculated to lead to the discovery of admissible evidence.” Lindsey v. PennDOT, 23 D.&C.3d 202 (1982). The facts and circumstances of each particular cause of action will frame the proper scope of discovery. See Stenger v. Lehigh Valley Hospital Center, 530 Pa. 426, 609 A.2d 796 (1992). A court will only place limitations on the scope of discovery when it concludes that a matter which is sought as discoverable is privileged, irrelevant, or specifically prohibited by the rules.

While a litigant’s right to discovery is far-reaching, this right is not absolute. Taylor v. West Penn Hospital, 48 D.&C.3d 178 (1987). The limitations contained in Pa.R.C.P. 4011 define the bounds of the scope of discovery. Specifically, Pa.R.C.P. 4011(b) prohibits any [143]*143discovery which could cause “unreasonable annoyance, embarrassment, oppression, burden, or expense to a deponent or any person or party,” and Rule 4011(e) prohibits the making of an “unreasonable investigation by the deponent or any party or witness.”

In the province of discovery, Pennsylvania case law recognizes an individual’s interest in avoiding the disclosure of personal matters which are within a constitutionally protected sphere of privacy. In re June 1979 Allegheny County Investigating Grand Jury, 490 Pa. 143, 415 A.2d 73 (1980).1 The United States Supreme Court in Walen v. Roe, 429 U.S. 589, 599-600, 97 S.Ct. 869, 876, 51 L.Ed.2d 64, 73 (1976), found that an individual’s right to privacy necessarily embodies two types of privacy interests, “[o]ne is the individual’s interest in avoiding disclosure of personal matters, and another is the interest in independence in making certain kinds of important decisions.” This protection in avoiding the disclosure of personal matters, however, is also not absolute, and the competing interests of each party must, therefore, be balanced. See United States v. Westinghouse Electric Corp., 638 F.2d 570 (3d Cir. 1980) (employee medical records are within ambit of materials entitled to privacy protection but this right must be balanced against society’s public health concerns); Fabio v. Civil Service Commission of the City of Philadelphia, 489 Pa. 309, 414 A.2d 82 (1980) (in Pennsylvania, only a compelling state interest will override one’s privacy rights).

[144]*144There can be no question but that some part of the plaintiff’s extensive medical history may be of substantial relevance to the issue at hand. In the same light, however, there can also be no question but that some parts of the plaintiff’s medical history may be not only irrelevant to the present action but also of a highly private and personal nature. The defendant’s counsel in argument has so admitted. Therefore, it is agreed by both parties that within the records which are subject to the subpoena are matters which are fully discoverable and matters which are fully undiscoverable. The plaintiff’s counsel obviously seeks to keep the matters which are fully undiscoverable from the opposing counsel’s review. Opposing counsel concedes that he has no use for these undiscoverable matters, but makes known his concern that fully discoverable matters may be well be kept from him in the mistaken belief that they are undiscoverable. The question becomes whether there can be a reconciliation of both, the defendant’s need for all relevant, non-privileged matters and the plaintiff’s right to keep private all of her medical records which contain intimate matters of a personal nature which are not germane to the present action.

We began an analysis of this matter by first noting that the plaintiff is impliedly considered to have consented to the disclosure of information which is considered confidential in “civil matters brought by such patient, for damages on account of personal injuries.” 42 Pa.C.S. §5929. The defendant would interpret this as allowing for the discovery of everything in the plaintiff’s medical records irrespective of the fact that information which will be discovered will admittedly have no significance or relationship to the present action. We consider such an interpretation to be unacceptable and overreaching. See DeLuca v. Leon, 1 D.&C.3d 185 (1977) (request to compel production of all plaintiff’s medical records refused). The purpose underlying the [145]*145implied waiver policy is that “it is inconsistent for a patient to base a claim upon his medical condition and then use the privilege to prevent the opposing party from obtaining and presenting conflicting evidence pertaining to that condition.” Moses v. McWilliams, 379 Pa. Super. 150, 181, 549 A.2d 950, 966 (1988) (Cirillo, P.J., concurring and dissenting), citing Bond v. District Court, 682 P.2d 33, 38 (Colo. 1984). To allow the defendant the discovery of every shred of the plaintiff’s medical records, including that which will be unquestionably impertinent, does not further this policy.

We also make note of Pa.R.C.P. 4009 which allows a court to order a party to produce records which are in the “possession, custody or control of the party upon whom the request is served.” For purposes of the application of Rule 4009, an individual’s medical records may be considered as within the “control of the party.” Greyhound v.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Bandru v. Fawzen
46 Pa. D. & C.5th 1 (Lackawanna County Court of Common Pleas, 2015)

Cite This Page — Counsel Stack

Bluebook (online)
37 Pa. D. & C.4th 140, 1998 Pa. Dist. & Cnty. Dec. LEXIS 145, Counsel Stack Legal Research, https://law.counselstack.com/opinion/slayton-v-biebel-pactcomplcrawfo-1998.