Ohio Supreme Court

Stull v. Summa Health Sys.

December 10, 2024177 Ohio St. 3d 543

Summary

The Ohio Supreme Court held that factual ambiguities in an affidavit do not alone determine the applicability of the peer‑review privilege to a resident physician’s file and that the trial court has inherent authority to conduct an in‑camera review to resolve the privilege issue. Accordingly, the Court reversed the appellate judgment and remanded for further factual inquiry.