Ridenour v. Glenbeigh Hosp. (Summary)

PEER REVIEW PRIVILEGE – INCIDENT REPORT

Ridenour v. Glenbeigh Hosp., No. 100550 (Ohio Ct. App. May 15, 2014)

An Ohio appellate court affirmed a lower court’s decision granting a patient’s motion to compel production of an incident report that was prepared by a nurse at the hospital.  The patient, while under the hospital’s care, suffered a seizure, fell and sustained life-altering brain injuries.  The patient’s family sued the hospital for negligence and sought discovery of the incident report.  The Court of Appeals held that the report was not generated exclusively for peer review, citing the fact that the original document was forwarded and retained by the director of human resources and that the peer review committee only received a copy.  Thus, the lower court was correct in holding that the peer review privilege did not apply and compelling the production of the document.