State ex rel. Grandview Hospital & Medical Center v. Gorman

The court of appeals determined that Grandview’s complaint failed to state a claim in prohibition upon which relief could be granted. Grandview did not set forth facts showing that the common pleas court lacked jurisdiction in this situation. We agree and hold that a trial court, in the course of regulating discovery, has authority to direct an in camera inspection of hospital records despite claims of the medical review committee privilege under R.C. 2305.251.

“For a writ of prohibition to issue, a relator must ordinarily establish: (1) that the court against whom it is sought is about to…