Moore v. Grandview Hospital

In this case we are asked to determine the propriety of the expert testimony given by Daniel Moore’s treating physician, Lauren Vogel, D.O.

The admissibility of such testimony is governed by the statutory physician-patient privilege, R.C. 2317.02(B). R.C. 2317.02 states in pertinent part:

“The following persons shall not testify in certain respects:

“(B) A physician concerning a communication made to him by his patient in that relation or his advice to his patient but the physician may testify by express consent of the patient * * * or if the patient, his executor or administrator, files a…