99 N.Y.2d 528 (2003)
The physician-patient privilege under CPLR 4504(a) protects patient confidentiality, and grand jury subpoenas seeking medical records based on the ’cause or potential cause’ of injury, even if purportedly limited to injuries observable by a layperson, still require a medical determination and thus violate the privilege.
Summary
The New York Court of Appeals addressed whether grand jury subpoenas served on hospitals seeking medical records of patients treated for lacerations or puncture wounds, based on injuries “plainly observable to a lay person,” violated the physician-patient privilege. The District Attorney sought these records to identify a homicide suspect. The Court held that complying with the subpoenas would violate the privilege because determining the cause of the injuries requires medical evaluation, thus intruding upon the physician-patient relationship. This decision emphasizes the broad protection afforded by the physician-patient privilege in New York.
Facts
Following a homicide, the District Attorney served grand jury subpoenas on 23 hospitals, including New York City Health and Hospitals Corporation (HHC) facilities. The subpoenas requested records of Caucasian male patients, aged 30-45, treated for lacerations, puncture wounds, or other injuries caused by sharp objects between May 25th and May 26th, 1998. The subpoenas excluded “information acquired by a physician… in attending said patient in a professional capacity and which was necessary to enable said doctor… to act in that capacity.” HHC refused to comply, citing the physician-patient privilege.
Procedural History
The District Attorney moved to hold HHC in contempt for failing to comply with the subpoenas. HHC cross-moved to quash the subpoenas. The Supreme Court denied both motions but ordered HHC to submit the records for in camera inspection. The Appellate Division reversed and granted HHC’s motion to quash, finding that compliance would violate the physician-patient privilege. The Court of Appeals granted leave to appeal.
Issue(s)
Whether grand jury subpoenas seeking hospital records of patients treated for injuries, where the subpoenas are limited to injuries “plainly observable to a lay person,” violate the physician-patient privilege under CPLR 4504(a) when the determination of the injury’s cause requires medical evaluation.
Holding
No, because the determination of whether an injury falls within the scope of the subpoena (i.e., its cause) requires a medical determination and therefore violates the physician-patient privilege, even if the injury itself is purportedly observable by a layperson.
Court’s Reasoning
The Court emphasized the importance of the physician-patient privilege, noting its purpose is to encourage patients to seek medical care without fear of public disclosure, ensure candid record-keeping by medical professionals, and protect patients’ privacy. While the privilege does not extend to information obtained outside medical diagnosis and treatment, the subpoenas in this case inevitably called for a medical determination regarding the cause of the injury. The Court relied heavily on Matter of Grand Jury Investigation of Onondaga County, 59 N.Y.2d 130 (1983), which quashed a similar subpoena seeking records of patients treated for knife wounds. The Court reasoned that the subpoenas, by defining the class of records sought by the “cause or potential cause” of injury, required medical professionals to apply their professional skill or knowledge. Even the limitation to injuries