Lee v. Fairview Health Services
- David Doty
- 0:17-cv-00105
- U.S. District Court · District of Minnesota
- 6
In Lee v. Fairview, Judge Rau granted in part and denied in part Fairview’s discovery motion, limited authorizations, and denied fees.
Claire Jean Lee must provide the required discovery, initial disclosures, and properly limited medical authorizations unless she had already done so. Fairview Health Services and Fairview Southdale Hospital may seek authorizations only within the period set by the court, and Fairview did not receive the requested fees.
What happened
In Claire Jean Lee v. Fairview Health Services and Fairview Southdale Hospital, Fairview asked the court to require Lee to provide overdue discovery responses, initial disclosures, and medical and mental-health authorizations. Lee said that illnesses and other stressors affected her ability to respond and objected to the breadth of the requested authorizations.
The court ruled that the requested medical authorizations were too broad because the case centered on Lee’s January 10 and 11, 2015 hospital visit. It limited the authorizations to the five years before January 10, 2015, through the present, required Lee to identify providers and entities during that period, and ordered Fairview to provide partially completed forms when it knew relevant provider information. Lee also had to provide the required discovery, disclosures, and authorizations within 21 days if she had not already done so.
Judge Steven E. Rau granted in part and denied in part Fairview’s motion to compel. He denied Fairview’s request for fees, citing the partial ruling and Lee’s status as a person allowed to proceed without paying filing fees, while reminding Lee that she still had to follow the procedural rules.
The detailed version
- Lee v. Fairview Health Services · No. 0:17-cv-00105
- David Doty
- Aug. 20, 2018
Background
Lee brought claims under the Americans with Disabilities Act, the Emergency Medical Treatment and Active Labor Act, the Rehabilitation Act, the Minnesota Government Data Practices Act, and for intentional infliction of emotional distress. The claims arose from her visit to Fairview Southdale Hospital on January 10 and 11, 2015, for medical and psychiatric care.
Fairview moved to compel, meaning it asked the court to order Lee to provide discovery that Fairview said was missing or incomplete. Fairview sought Lee’s initial disclosures, answers to interrogatories and document requests, and medical and mental-health authorization forms covering providers Lee had seen during the previous ten years. Fairview also requested the fees and costs of bringing the motion.
Lee acknowledged that she needed to provide written discovery but said medical conditions and other stressors had interfered with her participation. She also objected that some requested authorizations concerned treatment from 15 to 20 years earlier or places where she had never received treatment. Lee said she had sent or planned to send some of the requested materials and objected to Fairview’s request for fees.
Court’s Analysis
The court applied Federal Rule of Civil Procedure 26(b)(1), which generally permits discovery of nonprivileged information relevant to a claim or defense and proportional to the needs of the case. The court found that Lee did not dispute the relevance of the requested discovery, but agreed that the proposed medical-author authorization scope was overly broad.
Because the central incident was Lee’s January 10 and 11, 2015 visit, the court ordered that medical authorizations be limited to the five years before January 10, 2015, through the present. Lee was required to identify providers and entities from which she sought treatment during that period. If Fairview knew of specific providers or entities for which Lee had not supplied authorizations, Fairview had to give her forms containing as much information as possible, such as the provider, entity, and applicable dates.
The court also ordered Lee, to the extent she had not already done so, to respond to Fairview’s written discovery, provide initial disclosures, and provide medical authorizations within 21 days of the order. The court denied Fairview’s request for fees. It explained that the motion was being granted in part and denied in part and that Lee had been granted permission to proceed without paying filing fees. The court nevertheless reminded Lee that her status as a self-represented party and her medical issues did not relieve her of the obligation to follow the federal and local procedural rules.
Disposition
Judge Steven E. Rau ordered that Fairview’s Motion to Compel Complete Discovery Responses and Complete Medical and Mental Health Authorizations was GRANTED in part and DENIED in part, consistent with the order. The court separately denied Fairview’s request for fees.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.