Jaime v. New York State Officers
- Sidney Stein
- 1:24-cv-00266
- U.S. District Court · Southern District of New York
- 3
In Luis Jaime v. New York State Officers, Judge Stein denied Jaime’s subpoena request and directed him to sign forms allowing defendants to obtain medical records.
Luis Jaime, the defendants, and the New York State Department of Corrections and Community Supervision.
What happened
In Luis Jaime v. New York State Officers, Luis Jaime, an incarcerated person without a lawyer, asked the court to issue a subpoena requiring the New York State Department of Corrections and Community Supervision to provide his medical records for discovery.
The court agreed that the records were relevant and important to Jaime’s claims of personal injury. But it found that signing medical-record authorization forms would likely be faster and would allow the defendants to obtain their own copies directly from the agency.
Judge Gary Stein denied the subpoena request and instructed Jaime to sign and return the authorization forms to the defendants. The defendants must give Jaime a complete and accurate copy of any records they obtain.
The detailed version
- Jaime v. New York State Officers · No. 1:24-cv-00266
- Sidney Stein
- Nov. 10, 2025
Background
Luis Jaime, who is incarcerated and representing himself, asked the court to issue a subpoena to the New York State Department of Corrections and Community Supervision (DOCCS) for his medical records. He said he needed the records to comply with his discovery obligations. Discovery is the process by which parties obtain information and documents relevant to a lawsuit.
Legal standard
The court cited 28 U.S.C. § 1915(d) and Federal Rule of Civil Procedure 45. Rule 45 generally requires the court clerk to issue a subpoena when a party requests one. The court also explained that federal courts may supervise an indigent party’s use of court-funded litigation procedures to prevent abuse of the court’s process or harassment of parties and nonparties. In reviewing a requested subpoena before service, courts may consider whether the requested information is relevant and material, whether it is necessary to prove the case, whether it duplicates evidence already available, and whether it can be obtained in a less burdensome way.
Court’s analysis
The court found that Jaime’s medical records were relevant and material because he alleged that the defendants’ conduct caused him personal injuries. The court nevertheless found that the proposed subpoena was not the preferred way to obtain the records. The defendants had already provided Jaime with medical-record authorization forms. If Jaime signed and returned those forms, the defendants could obtain the records directly from DOCCS. The court said this approach would likely be faster and would allow the defendants to secure their own copy of the records rather than receive them indirectly through Jaime.
Ruling
The court denied Jaime’s request for issuance of a subpoena to DOCCS. It instead instructed him to execute, meaning sign, the authorization forms and return them to the defendants so they could obtain the medical records directly from DOCCS. The court also stated that the defendants must provide Jaime with a full and accurate copy of any records they obtain.
Effect of the order
This order concerns the method of obtaining discovery and does not decide the underlying claims or defenses described in the opinion.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.