Discovery: Court Orders Internal Review of Quality Database

​An appellate court in Washington ruled that a hospital must provide redacted patient records that could be identified by an internal search of its quality assurance committee database to a plaintiff in a lawsuit alleging corporate negligence. The plaintiff claimed to have suffered a permanent neurological injury allegedly as a result of negligently administered intravenous (IV) therapy at the hospital. The decision reversed a lower court's ruling that the records were protected from disclosure by state law privilege for hospital quality improvement records.

The plaintiff, a former staff physician at the hospital, requested information describing instances of IV infusion complications or injuries at the hospital from 2000 to 2008. The court determined that the information requested was relevant to the claims asserted and that the hospital was capable of producing the requested information by performing a search of the quality assurance committee database, which would generate a list of cases involving complications with IV infusions, indexed by date and identification number. The only other way to retrieve this information would be to manually review patient...