Harris v. NYC Human Resources Administration
- John Cronan
- 1:20-cv-02011
- U.S. District Court · Southern District of New York
- 3
Harris v. City of New York: Judge Cronan denied the City’s requests for broader therapy records and to bar emotional-distress evidence at trial.
The ruling affected the City of New York’s effort to obtain broader Employee Assistance Program records from Mary L. Harris and to prevent her from presenting emotional-distress evidence at trial.
What happened
In Harris v. City of New York, the City asked the court to require Mary L. Harris to sign a broader authorization for access to all of her Employee Assistance Program therapy records. Harris opposed the request.
Harris had already signed an authorization covering Employee Assistance Program records from 2015 onward, in response to the City’s earlier request for medical and psychological records. The court found that seeking additional records was not proportional to the needs of the case, especially because the records became less relevant the farther back in time they went.
The court also denied the City’s alternative request to prevent Harris from presenting emotional-distress evidence at trial. Judge John P. Cronan stated that Harris had not disobeyed a clear discovery order and that the City had already explored her prior work-related stress and could address it again at trial.
The detailed version
- Harris v. NYC Human Resources Administration · No. 1:20-cv-02011
- John Cronan
- Apr. 7, 2025
Background
The City moved to compel Mary L. Harris to provide a HIPAA release authorization allowing the City to obtain all of her Employee Assistance Program (EAP) records. Harris opposed the motion.
The court explained that discovery generally may cover nonprivileged information relevant to a party’s claims or defenses and proportional to the needs of the case. In December 2022, the City had requested authorizations for Harris’s medical and psychological records for treatment received from 2016 to the present. Harris had provided an executed HIPAA authorization covering EAP records from 2015 to the present.
Court’s Analysis
The City argued that it could not agree to a limiting date without obtaining a complete history of Harris’s therapy concerning work-related stress at the City’s Brooklyn CASA location. The court found that the City’s original discovery request itself included a limiting date, and Harris had complied with that request. The court also recognized that records from years before Harris’s allegations might have some remaining relevance, but concluded that their relevance to an emotional-distress claim became more uncertain as the records became older. Given the existing authorization reaching back to 2015, the court ruled that the City’s additional request was not proportional to the needs of the case.
The City alternatively asked the court to prevent Harris from presenting any evidence about emotional distress at trial. The court rejected that request because Harris had not disobeyed a clearly stated court order requiring specific discovery. The court also found no resulting prejudice to the City because the City had apparently explored Harris’s preexisting work-related stress during her second deposition and would have another opportunity to address the issue at trial.
Ruling
Judge John P. Cronan denied the City’s motion for production of an expanded HIPAA release. The court also denied the City’s alternative request to bar Harris from introducing emotional-distress evidence at trial. The Clerk of Court was directed to close Docket Number 185.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.