People v. Hart

The State appeals, pursuant to Supreme Court Rule 604(a)(1) (107 Ill. 2d R. 604(a)(1)), from an order of the circuit court of De Kalb County granting defendant’s, Timothy R Hart’s, motion to quash numerous subpoenas duces tecum. The State essentially raises two issues on appeal: (1) whether the use of the subpoenas duces tecum was proper; and (2) whether defendant’s medical records were protected by the physician-patient privilege.

Defendant was charged by information with four counts of reckless homicide (Ill. Rev. Stat. 1987, ch. 38, par. 9 — 3) and four counts of driving under the influence…