Griffith v. Aultman Hosp. (Slip Opinion)
146 Ohio St. 3d 196
| Ohio | 2016Background
- Patient Howard Griffith underwent surgery at Aultman Hospital, was continuously cardiac‑monitored, suffered an unexplained collapse on May 6, 2012, and died after withdrawal of life support.
- Gene’a Griffith (daughter/personal representative) requested Howard’s complete medical record; hospital produced records from its medical‑records department but initially withheld cardiac monitoring strips and some nursing records.
- Hospital later produced some monitoring strips but maintained that monitoring printouts generated/kept by Risk Management after discharge were not part of the medical record.
- Griffith sued under R.C. 3701.74 to compel production; trial court granted summary judgment to the hospital; Fifth District affirmed, reasoning the medical record consists of what the medical‑records department maintains.
- Ohio Supreme Court granted review to decide whether R.C. 3701.74(A)(8) limits "medical record" to data stored in the medical‑records department and the meaning of "maintained."
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| How to define "medical record" under R.C. 3701.74(A)(8) | Griffith: statute does not permit hospitals to limit medical records to what is in the medical‑records department; all data generated/kept in treatment process that pertains to medical condition is included | Hospital: "maintain" implies managerial choice to include records in a discrete set (medical‑records department); data kept elsewhere (e.g., Risk Management) are not part of the medical record | Court: "medical record" means data generated in the course of treatment that a health‑care provider has decided to keep; physical location is irrelevant; "maintain" = decision to keep/preserve data |
| Does R.C. 3701.74 require a requester to state a purpose for access? | Griffith: statute does not require stating a reason | Hospital/Fifth Dist.: framed statute as enabling patient access for clinical reasons (e.g., second opinion) and not as broad discovery | Court: statute requires only a signed written request dated within one year; no reason required |
| Whether hospital met summary‑judgment burden of producing the entire medical record | Griffith: hospital failed to produce monitoring strips and nursing records that qualify as medical records | Hospital: certified production of records from medical‑records department sufficed; disputed strips were retained for risk‑management, not part of medical record | Court: remanded — record was insufficient under correct legal definition; hospital must show no genuine issue of material fact that it produced the complete medical record |
| Relevance of records generated/kept by Risk Management after discharge | Griffith: such records can be medical records if generated in treatment and retained by provider | Hospital/Dissent: Risk Management post‑death printouts are not generated/maintained "in the process of the patient's health care treatment," so they are not medical records | Court: physical location or department not dispositive; must determine on remand whether the Risk Management materials were data generated and retained in the treatment process (if so, they qualify) |
Key Cases Cited
- State ex rel. United States Steel Corp. v. Zaleski, 786 N.E.2d 39 (Ohio 2003) (legislative intent is paramount in statutory interpretation)
- Weaver v. Edwin Shaw Hosp., 819 N.E.2d 1079 (Ohio 2004) (use ordinary meaning of statutory terms)
- Boley v. Goodyear Tire & Rubber Co., 929 N.E.2d 448 (Ohio 2010) (apply statute as written)
- Armstrong v. John R. Jurgensen Co., 990 N.E.2d 568 (Ohio 2013) (do not add or delete statutory language)
- Cleveland Elec. Illuminating Co. v. Cleveland, 524 N.E.2d 441 (Ohio 1988) (give effect to the words actually used in a statute)
- Dresher v. Burt, 662 N.E.2d 264 (Ohio 1996) (moving party’s initial summary‑judgment burden to identify absence of genuine issue of material fact)