Kentucky Supreme Court

Saint Elizabeth Medical Center, Inc. v. Hon. Patricia M. Summe

June 25, 2026

Summary

The Court held that completed physician credentialing applications are records of a designated professional review function and are generally privileged under KRS 311.377(2). That privilege does not extend to information independently discoverable under KRS 311.377(3), so the trial court must separately evaluate the contents under that exception. The Court reversed the Court of Appeals, vacated the trial court's discovery order, and remanded for that statutory analysis.