New York Court of Appeals
In the Matter of Grand Jury Investigation in New York County; New York City Health and Hospitals Corporation…
October 15, 200298 N.Y.2d 525
Summary
The New York Court of Appeals affirmed the Appellate Division's order quashing grand jury subpoenas served on hospitals, holding that the physician‑patient privilege under CPLR 4504(a) bars disclosure of the requested medical records. The Court found that the subpoenas required a medical determination of injury causation, which is protected, and that no statutory exceptions applied.