Walker v. Taco Bell, 2016 Ohio 124

Plaintiff Anthony Walker sued Taco Bell and the Ohio Bureau of Workers’ Compensation seeking to participate in the workers’ compensation fund for an alleged workplace injury.
During discovery, the Bureau requested Walker sign medical-record releases for three providers; Walker refused pending an agreement that he could later claim privilege for some records.
The Bureau moved to compel production; Walker opposed and filed a protective-order motion seeking a ruling that non-causally related records were privileged.
The trial court granted the Bureau’s motion to compel and denied Walker’s protective order.
Walker appealed the discovery order, arguing that compelled disclosure of privileged records is immediately appealable because "the bell cannot be unrung." The Bureau moved to dismiss for lack of a final, appealable order.
The appellate court dismissed the appeal for lack of jurisdiction under Ohio law, holding Walker failed to show an immediate appeal was necessary under R.C. 2505.02(B)(4).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the order compelling disclosure of allegedly privileged medical records is a final, appealable order	Walker: once privileged records are disclosed the harm is irreparable, so immediate appeal is required ("bell cannot be unrung")	Bureau: the discovery order is not a final appealable order; Walker can raise privilege on appeal after final judgment	Dismissed for lack of jurisdiction because Walker did not establish that an immediate appeal was necessary under R.C. 2505.02(B)(4)(b)

Smith v. Chen, 142 Ohio St.3d 411, 2015-Ohio-1480, 31 N.E.3d 633 (Ohio 2015) (an appellant seeking to appeal a discovery order compelling disclosure of privileged material must establish an immediate appeal is necessary to afford a meaningful and effective remedy)