Colorado Medical Board v. Office of Administrative Courts

1 We issued a rule to show cause under C.A.R. 21 to decide whether the district court abused its discretion in holding that, as a matter of law, section 12-36.5-104(10)(a), C.R.S. (2013), protects professional review committee records from subpoena or discovery and admissibility in "civil suits," but not administrative proceedings. We hold that section 12-36.5-104(10)(a) protects the records of a professional review committee from all forms of subpoena or discovery. The statute further protects the records from admissibility in civil suits. We also hold that the term "civil suit" includes…