Disclosure of Medical Information for Patients Who Are Not Parties to a Lawsuit
Physician-patient privilege barred disclosure of medical information for patients who were not parties to the action:
In Dorris v. Detroit Osteopathic Hosp, 220 Mich. App. 248, 250; 559 N.W.2d 76 (1996), the plaintiff in a medical malpractice action sought the name of the patient who shared her hospital room because she believed this person would corroborate plaintiff's allegation that plaintiff refused a certain medication. 220 Mich. App. at 249-250.
This Court held that Schechet was binding precedent that barred disclosure of a patient's name. 220 Mich. App. at 251-252.
The Supreme Court of Michiganand affirmed this Court's decision:
The language of 2157 is clear in its prohibition of disclosure of privileged information.
In accordance with prior rulings of this Court, particularly Schechet, that the purpose of the privilege is to encourage patients' complete disclosure of all symptoms and conditions by protecting the confidential relationship between physician and patient, we find requiring the defendant hospitals to disclose the identity of unknown patients would be in direct contradiction of the language and established purpose of the statute. 460 Mich. at 37.