Griffith v. Aultman Hosp.

Appellant’s father (Decedent) died after receiving surgery at Aultman Hospital. Appellant requested a copy of Decedent’s complete medical record. The Hospital produced the medical record that existed in the medical-records department. Dissatisfied with the Hospital’s response, Appellant filed this action to compel the production of Decedent’s complete medical record. The trial court granted summary judgment in favor of the Hospital, concluding that the Hospital had produced the requested medical record, as defined by Ohio Rev. Code 3701.74(A)(8). The court of appeals affirmed, concluding that the term “medical record” as that term is used in Ohio Rev. Code 3701.74 does not include all patient data but consists only of information maintained by the medical-records department. The Supreme Court reversed, holding (1) data that was generated in the process of the patient’s healthcare treatment and that pertains to the patient’s medical history, diagnosis, prognosis, or medical condition qualifies as a “medical record”; but (2) “medical record” means any patient data “generated and maintained by a health care provider” without limitation as to the physical location or department where it is kept. Remanded. View "Griffith v. Aultman Hosp." on Justia Law