State ex rel. William A. Stinson v. The Honorable Ted House

Summary

The Supreme Court of Missouri made permanent a preliminary writ of prohibition preventing a trial court from compelling William Stinson to execute an authorization for disclosure of his medical and psychological records. The court held that the records were protected by the physician-patient privilege, had not been waived, and remained undiscoverable even though they were relevant to a negligent-entrustment claim against Stinson's parents. Disclosure of privileged records would have caused irreparable injury not repairable on appeal.

Holdings

1. Medical records containing information acquired from Stinson by physicians or psychologists to evaluate, diagnose, and treat alcohol, drug, or substance-abuse conditions were protected by Missouri's physician-patient privilege and were not discoverable.
2. Stinson did not waive the physician-patient privilege merely by denying liability and defending against the wrongful death action.
3. The relevance of privileged medical records to a negligent-entrustment claim does not make them discoverable.
4. The physician-patient privilege applies even when the confidential medical information is intended to be used against someone other than the patient.
5. Prohibition was appropriate because compelling production of privileged materials would cause irreparable injury that could not be repaired on appeal.

Questions Presented

1. Whether the requested medical and psychological records were protected by Missouri's physician-patient privilege.
2. Whether Stinson waived the physician-patient privilege by denying liability and defending the wrongful death action.
3. Whether the relevance of the records to the negligent-entrustment claim or their intended use against Stinson's parents removed the records from the privilege.
4. Whether prohibition was an appropriate remedy to prevent enforcement of the trial court's order compelling execution of the medical-records authorization.

Disposition

writ_granted