Copin Sastrawidjaya, V Maureen Mughal

Citations: 196 Wash. App. 415; 384 P.3d 247Docket: 47777-7-II

Court: Court of Appeals of Washington; October 18, 2016; Washington; State Appellate Court

Original Court Document: View Document

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The Washington State Court of Appeals addressed whether a trial court can compel personal injury plaintiffs to sign stipulations and authorizations for the defendant to obtain their medical records. The court concluded that civil discovery rules do not grant such authority, ruling that the trial court erred in ordering plaintiffs Copin Sastrawidjaya and Rianne Matheos to sign these stipulations for defendant Maureen Mughal. Consequently, the court reversed the trial court’s discovery order and remanded the case for further proceedings.

In April 2014, Sastrawidjaya and Matheos initiated a lawsuit against Mughal for injuries sustained in an automobile accident attributed to her negligence. Mughal requested the plaintiffs' medical records through discovery, but they only provided records in their possession and identified additional medical providers. When Sastrawidjaya and Matheos refused to sign the stipulated authorizations for the release of their medical records, Mughal moved to compel compliance, arguing that the records were relevant and discoverable. The trial court ordered the plaintiffs to sign the stipulations, leading to their motion for discretionary review, which was granted by a court commissioner.

The court reviewed the discovery orders for abuse of discretion, clarifying that a trial court abuses its discretion when its decisions are based on an erroneous legal interpretation or analysis.

Reviewing the trial court's authority to compel discovery reveals that it lacked the power to mandate Sastrawidjaya and Matheos to sign medical record stipulations. Both parties contended that such stipulations are not an authorized discovery method under the civil rules. Specifically, CR 26 outlines permitted discovery methods, including depositions, interrogatories, document production, physical and mental examinations, and requests for admission, but lacks a "catch-all" provision for other methods. Consequently, the trial court's order for the stipulations exceeded its authority under CR 26 because mandatory stipulations for medical records are not listed as a permissible discovery method.

Mughal argued that CR 34(a)(1) would allow her to require the stipulations as part of document production requests. However, CR 34(a)(1) only mandates that a party produce documents within their possession and does not require stipulations to facilitate another party's independent access to those documents. If Sastrawidjaya and Matheos failed to produce medical records, the proper course of action would have been to file a motion to compel under CR 37(a). CR 37 provides for sanctions if a party disobeys a court order compelling discovery but does not permit motions to compel stipulations or authorize such stipulations as sanctions. Thus, the court confirmed it lacked authority under CR 26, CR 34, and CR 37 to compel the signing of medical record stipulations.

The trial court does not possess the inherent authority to compel the production of medical records through stipulations signed by the plaintiffs, Sastrawidjaya and Matheos. Mughal's reliance on case law from other jurisdictions does not substantiate her claim, as she fails to provide relevant Washington authority. Although some out-of-state cases support the enforcement of medical record authorizations, there is no consensus on this issue. The court emphasizes that a stipulation is inherently voluntary and cannot be compelled by a trial court. 

Additionally, while Mughal acknowledges alternative methods for obtaining medical records, such as issuing subpoenas or compelling the attendance of records custodians, the fact that the records are located in Canada complicates the situation. However, Washington court rules specifically allow for compliance with local laws when subpoenas are issued in foreign jurisdictions. Consequently, the court rules do not permit bypassing these requirements by forcing the plaintiffs to sign stipulations. 

The conclusion reached is that the trial court erred in ordering the plaintiffs to sign stipulations for medical record release, and if they refuse, Mughal must follow the established court procedures to obtain the records. The court reverses the trial court’s order and remands for further proceedings.