Sunrise Hosp. v. Eighth Jud. Dist. Ct.

Summary

The Nevada Supreme Court held that the federal Patient Safety and Quality Improvement Act’s privilege for identifiable patient safety work product is absolute and cannot be waived, and that the district court erred in finding a waiver. Accordingly, the court granted the petition for a writ of prohibition and instructed the lower court to first determine whether the contested testimony involves identifiable or non‑identifiable patient safety work product before ruling on the motion to compel. The decision also affirmed the court’s authority to issue writ relief when a lower court exceeds its jurisdiction on privileged information.