Opinion No.

Honorable W. J. Estelle, Jr. Director Texas Department of Corrections Huntsville, Texas 77340

Re: Whether Texas Department of Corrections inmate may review his own medical records

Dear Mr. Estelle:

You have requested our opinion as to whether an inmate of the Texas Department of Corrections [hereinafter TDC] is entitled to review his own medical records held by the department.

It has been suggested that an inmate might have a constitutional or common law right to inspect his own medical records. In Paine v. Baker, 595 F.2d 197 (4th Cir.), cert. denied, 444 U.S. 925 (1979), the court considered a…