Williams v. State
2012 Ind. App. LEXIS 8
| Ind. Ct. App. | 2012Background
- Williams was arrested for possession of methadone and alprazolam with a claimed need for a valid prescription as a defense.
- He subpoenaed the Indiana Board of Pharmacy for his own prescription records from INSPECT, a Board-maintained database.
- Board moved to quash the subpoena, arguing confidentiality under Indiana Code §35-48-7-11.1 and related subsections.
- At hearings, Williams initially could not identify pharmacies, then testified he knew doctors but not where prescriptions were filled.
- Trial court granted the Board’s motion to quash and certified the ruling for interlocutory appeal.
- On appeal, Williams argued records are not privileged, the request is sufficiently particular, and the records are material to his defense; the Board argued the opposite.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Williams’s records may be disclosed despite confidentiality provisions | Williams seeks his own records to build a complete defense | Board asserts statutory confidentiality and limited disclosure | No; the court held Williams waived privilege and records are discoverable under three-part test |
| Whether the subpoena satisfies the three-part discoverability test (particularity, materiality, paramount interest) | Williams’s request is sufficiently particular and material to defense | Board contends lack of particularity and paramount interest in nondisclosure | Yes; the subpoena met particularity and materiality, and no paramount interest supported nondisclosure |
| Whether the Board’s confidentiality statute defeats discovery when the patient seeks to present a complete defense | Privileging statutes do not bar necessary defense discovery | Confidentiality provisions prevent disclosure to non-listed recipients | No; confidentiality provisions yield to the patient’s right to present a complete defense; trial court abused discretion |
Key Cases Cited
- In re Crisis Connection, Inc., 949 N.E.2d 789 (Ind. 2011) (three-part discoverability test for criminal records; privilege limits apply)
- Williams v. State, 819 N.E.2d 381 (Ind. Ct. App. 2004) (balance of relevance, availability, burden, and interest in discovery)
- Collins v. Bair, 256 Ind. 230, 268 N.E.2d 95 (1971) (physician-patient privilege may be waived by pursuit of records)
- Ley v. Blose, 698 N.E.2d 381 (Ind. Ct. App. 1998) (privilege may be waived by the patient implicitly or expressly)
- Schuller v. State, 625 N.E.2d 1243 (Ind. Ct. App. 1993) (valid prescription defense to possession of controlled substances)
- Moore v. State, 839 N.E.2d 178 (Ind. Ct. App. 2005) (discovery rulings reviewed for abuse of discretion)
- Cline (In re WTHR-TV), 693 N.E.2d 1 (Ind. 1998) (trial rule discovery governed by Rule 26; broad relevance standard)