Holland v. Dayton Children's Hosp.

Citations

• 2026 Ohio 1678

Syllabus

The trial court erred by limiting its own power to control the discovery process. The trial court should have conducted further inquiry to determine whether the peer-review privilege applies to two emails sent by appellant's employees. The trial court did not abuse its discretion when it found that appellant failed to establish that the two emails are protected by the work-product doctrine. Judgment reversed in part and affirmed in part.