Howell v. Park E. Care & Rehab.

Citations

• 2018 Ohio 2054

Syllabus

In camera review discovery privilege motion to compel R.C. 2317.02 R.C. 2305.353 HIPAA R.C. 3721.02. The trial court did err in ordering discovery of nursing home's incident reports and medical records pertaining to nonparty nursing home patient who allegedly assaulted plaintiff's decedent, because the trial court did not first conduct an in camera review of the disputed documents.