Bay Area Health District v. Griffin

Plaintiff brought a declaratory judgment action to determine whether it was required under the public records law, ORS 192.410-192.500, to disclose a portion of a report concerning a hospital operating room study. The trial court determined that pages 9 through 12 of the report were not exempt from disclosure and ordered their disclosure.1 Plaintiff appeals.

The issue is whether those pages meet the requirements for exemption from disclosure as an “advisory” communication under ORS 192.500(2)(a), a “confidential” communication under ORS 192.500(2) (c) or a “privileged” communication concerning…