Robinson v. Minnesota, State of

Background

Tony Terrell Robinson alleges that defendants failed to properly treat an ankle injury and associated pain he suffered while incarcerated at the Minnesota Department of Corrections Lino Lakes Correctional Facility. He seeks damages for physical pain and emotional suffering.

Centurion of Minnesota, LLC, Jeanne Luck, and Stephen Dannewitz served Robinson with requests under Federal Rule of Civil Procedure 34 for his medical records, including a medical authorization. Robinson refused to produce the documents and sign the authorization, objecting that the requests were overbroad, privileged, and irrelevant. Centurion and Luck filed one motion to compel, and Dannewitz filed a substantially similar motion.

Court’s reasoning

The court explained that discovery generally covers nonprivileged information relevant to a party’s claim or defense. It found Robinson’s medical records clearly relevant because the case concerns his physical and emotional injuries. The records were therefore important evidence for resolving the case through settlement or a decision on the merits.

The court ordered Robinson to sign the medical authorization, but it did not order the defendants to obtain direct release of his medical records without his consent. The court also noted Robinson’s prior reluctance to provide authorization and stated that he should consider whether he wished to continue with the case.

Rulings

The motion to compel filed by Centurion and Luck was granted in part and denied in part. Robinson was required to provide them with a signed authorization, while their request for an order releasing his medical records directly to them was denied.

Dannewitz’s motion to compel was also granted in part and denied in part. Robinson was required to provide Dannewitz with a signed authorization, but Dannewitz’s request for fees and costs was denied. The court found that requiring Robinson, who was incarcerated, represented himself, and had been granted permission to proceed without prepaying filing fees, to pay those expenses would be unjust.

The order also required Centurion, Luck, and Dannewitz to provide Robinson with copies of the medical records they received as a result of the order. The order states that if Robinson failed to provide signed authorizations within ten days, the court would make a recommendation for dismissal for failure to prosecute. The body of the opinion separately refers to a two-week deadline.