Ex parte McCollough
In Ex parte McCollough, 747 So. 2d 887 (Ala. 1999) a majority of this Court held that, under 6 -5-551 as it then read, the plaintiff was entitled to discover information related to other acts and omissions by the defendant nursing home that were relevant to the plaintiff's allegations that the nursing home had negligently hired, trained, and supervised its employees.
The nursing home had argued that the requested discovery was prohibited by 6-5-551, which at the time applicable in McCullough had prohibited a "plaintiff ... from conducting discovery with regard to any other act or omission or from introducing at trial evidence of any other act or omission." This Court concluded that the requested information was "discoverable within the terms of 6-5-551." 747 So. 2d at 892.
McCollough recognized that a claim against a health-care provider alleging negligent hiring, training, and supervision is an "action ... for breach of the standard of care" governed by 6-5-551.