Griffith v. Aultman Hosp., 2014 Ohio 1218

Griffith, executrix for the estate of Howard Griffith, sued Aultman Hospital for access to his medical records under R.C. 3701.74 after May 2012 treatment and death.
Griffith alleges missing monitoring strips and nursing records from May 6, 2012, were not produced.
Griffith obtained some records but disputed whether all records were provided, prompting a 2013 Civ.R. 56 motion for summary judgment by Aultman.
Director of Medical Records testified that the hospital defines a medical record as documents provided to the medical records department, excluding some rhythm strips.
The trial court granted summary judgment, holding Aultman produced Griffith’s medical record as defined by R.C. 3701.74(A)(8).
Griffith appeals, arguing misdefinition of medical records and denial of discovery; the dissent contends broader access is required.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether production of the medical record complied with R.C. 3701.74	Griffith asserts incomplete record; hospital definition too narrow	Aultman produced what it maintains as the medical record under statute	No genuine issue; summary judgment affirmed
Whether Civ.R. 56(F) discovery should have been allowed before ruling on summary judgment	Additional discovery needed to locate other records (e.g., from Risk Management)	Requested materials either not medical records or already produced	No abuse of discretion; discovery denial affirmed

Dresher v. Burt, 75 Ohio St.3d 280 (Ohio 1996) (summary-judgment standard; burden shifting)
Mitseff v. Wheeler, 38 Ohio St.3d 112 (Ohio 1988) (specific facts required to oppose summary judgment)
Beegle v. Amin, 156 Ohio App.3d 533 (Ohio App.3d 2004) (discretion in Civ.R. 56(F) continuance)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (Ohio 1983) (abuse-of-discretion standard)
Vahila v. Hall, 77 Ohio St.3d 421 (Ohio 1997) (Dresher framework for summary judgment)