Amber Edwards, Petitioner v. Larry D. Thomas, M.d., Respondents

Summary

The court held that Florida's constitutional Amendment 7 eliminates all discovery restrictions on records relating to any adverse medical incident, not merely restrictions previously imposed by statute. It further held that externally obtained peer-review reports qualified as records made or received in the course of business and were discoverable, including any fact work product they contained; the court did not decide questions concerning opinion work product or attorney-client communications because the record presented neither. Justice Lawson, dissenting, would have upheld protection for expert reports prepared at counsel's request in anticipation of imminent litigation.