Williams v. City of Philadelphia (Summary)

PEER REVIEW PRIVILEGE

Williams v. City of Philadelphia, No. 08-1979 (E.D. Pa. Nov. 4, 2014)

fulltextThe District Court for the Eastern District of Pennsylvania required a company to produce mortality and sentinel event reviews in a class action suit brought by prison inmates.

Prison inmates alleged that overcrowding and triple-celling resulted in a dangerously unhealthy and unsafe environment, amounting to unconstitutional conditions of confinement. The prison inmates submitted a discovery request to the City of Philadelphia, seeking mortality and sentinel event reviews for the deaths of those in custody between the dates of January 2012 and December 2013. The city then sought to obtain the requested information from a contracted medical services provider. However, the medical services provider refused to turn over the documents, arguing that the documents are not discoverable because they are privileged and protected under the state’s peer review privilege law.

The court upheld the long-standing practice of refusing to recognize the peer review privilege in the federal court, finding that the medical services provider made no significant showing as to why the reviews should be withheld from discovery. The court also determined that the safety and efficiency of the prison system were sufficiently important, outweighing any potential harm that may be caused by disclosure.