Carter-Mixon v. City of Tacoma

W.D. Wash.9/20/2022
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                      UNITED STATES DISTRICT COURT                           
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                    WESTERN DISTRICT OF WASHINGTON                           
                              AT TACOMA                                      
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     MONET CARTER-MIXON, et al.,        CASE NO. C21-05692-LK                
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                    Plaintiffs,         REDACTED ORDER GRANTING              
12         v.                            IN PART, DENYING IN PART,            
                                        AND DEFERRING IN PART                
13    CITY OF TACOMA, et al.,            TELEPHONIC MOTION TO                 
                                        COMPEL RELEASE OF MEDICAL            
14                   Defendants.         RECORDS                              
15                                                                            

16       This matter comes before the Court on Defendant Timothy Rankine’s telephonic motion 
17  to compel production of Manuel Ellis’s medical records from providers who have declined to 
18  produce them in response to subpoenas. The Court denied Officer Rankine’s first two motions to 
19  compel, Dkt. Nos. 55, 64, because the parties failed to meet and confer before the motions were 
20  filed. Dkt. Nos. 57, 71. Two weeks after the Court denied Officer Rankine’s second motion to 
21  compel, counsel for Plaintiffs notified the Court that the parties remained at an impasse in their 
22  discovery dispute, and requested a telephonic conference with the Court to resolve the dispute 
23  pursuant to Local Civil Rule 7(i) (“[A] motion may be heard by telephone without the filing of 
24  motion papers.”). The Court held the telephone conference on September 19, 2022. Dkt. No. 75. 
1  During that conference, the parties requested that the Court consider their most recent briefing on 
2  the issue, Dkt. Nos. 64–68, as incorporated by reference in the telephonic motion, and the Court 
3  accordingly considers that briefing and the supplemental declaration, Dkt. No. 74, in resolving the 
4  telephonic motion. For the reasons set forth below, the Court grants the motion in part, denies it in 

5  part, and defers it in part.                                              
6                          I.   BACKGROUND                                   
7       On March 4, 2020, Manuel Ellis died while in police custody. Dkt. No. 22 at 7, 12–13; 
8  Dkt. No. 65-1 at 11. His mother, Marcia Carter, and his sister, Monet Carter-Mixon,1 sued the City 
9  of Tacoma, Tacoma Police Officers (including Officer Rankine), Pierce County, and Pierce 
10  County Sheriff Deputies, alleging among other things that the defendant police officers’ and sheriff 
11  deputies’ excessive force against Mr. Ellis in their encounter with him resulted in his death. Id. at 
12  1–4, 24–29. Defendants counter that intoxication caused or contributed to Mr. Ellis’s death. Dkt. 
13  No. 23 at 21; Dkt. No. 48 at 22; Dkt. No. 49 at 21–22; Dkt. No. 50 at 19.  
14       In May and June 2022, Officer Rankine served subpoenas for the production of Mr. Ellis’s 

15  medical and mental health records from numerous facilities. Dkt. No. 65-8 at 1–2, 6, 9–29.2 The 
16  subpoenas requested the providers’ “complete file” on Mr. Ellis, “including but not limited to any 
17  and all medical records, chart notes, diagnostic reports, lab reports, test results, imaging, reports, 
18  orders,  photographs,  videos,  correspondence,  pharmacy  prescriptions,  and  billing  records 
19  regardless of whether the records were generated by you or provided to you.” See, e.g., Dkt. No. 
20  65-8 at 27.                                                               
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22  1 Ms. Carter-Mixon brings claims in her capacity as the personal representative of Mr. Ellis’s estate. Id. at 3–4, 28. 
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   2 It is unclear to how many facilities Officer Rankine sent subpoenas. His notices of intent to serve subpoenas list 14 
   entities. Dkt. No. 65-8 at 1–2, 6. He has filed five letters purporting to attach subpoenas, but multiple copies of those 
   subpoenas are addressed to DSHS. Id. at 9–29. The most recent motion he has filed with this Court seeks to compel 
24  responses from eight providers. Dkt. No. 64 at 9.                         
1       Washington State Department of Social and Health Services (“DSHS”), Pierce County 
2  Sheriff’s Department-Corrections Bureau, Greater Lakes Mental Healthcare, Comprehensive Life 
3  Resources, and Sea Mar Rehabilitation objected to the subpoenas as follows: 
4    •  Greater Lakes Mental Healthcare stated that it required a properly executed authorization 

5       or a court order to release the records pursuant to “C.F.R. 45(C) [sic],  , 
6       RCW 70.02.230 2o [sic], and RCW 5.56.010,” and that any authorization or court order 
7       must meet the requirements of Section 70.96A.020 of the Revised Code of Washington3 
8       and         . Dkt. No. 65-9 at 1.                                    
9    •  Comprehensive Life Resources stated that it required a “judicially signed subpoena” or 
10       signed authorization to release the records. Id. at 2.               
11    •  Washington State DSHS stated that it required authorization or a court order that complied 
12       with applicable confidentiality laws, including 45 C.F.R. § 164.508 and Wash. Rev. Code 
13       § 70.02.030(3). Id. at 3.                                            
14    •  Sea Mar responded that it required a court order under  . Id. at 5.  

15    •  Pierce County Jail responded that the requirements of Wash. Rev. Code §§ 70.02 et seq. 
16       and 70.48 et seq. had to be satisfied before it could release the records. Id. at 6. 
17       Counsel for Officer Rankine spoke with representatives from each of these five facilities 
18  as well as                   , Fairfax Behavioral Health, and   ,         
19  and each representative indicated that they required a signed release or a court order to release the 
20  records. Dkt. No. 65 at 3–4.                                              
21       Counsel have met and conferred but have been unable to resolve the dispute. Dkt. No. 74 
22  at 1–2. Plaintiffs’ counsel explained during the telephone conference that Ms. Carter-Mixon, the 
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   3 Section 70.96A.020 of the Revised Code of Washington has been repealed. 2016 Wash. Legis. Serv., 1st sp. sess., 
24  ch. 29, § 301.                                                            
1  personal representative of Mr. Ellis’s estate, has not signed an authorization to allow the parties to 
2  obtain the records because Officer Rankine’s request for records was too broad. 
3                           II.  DISCUSSION                                  
4  A.   Legal Standards                                                      

5       A  party  may  serve  a  subpoena  commanding  a  nonparty  “to  produce  documents, 
6  electronically stored information, or tangible things[.]” Fed. R. Civ. P. 45(a)(1)(C). The subpoena 
7  is subject to the relevancy requirements set forth in Federal Rule of Civil Procedure 26(b). See, 
8  e.g., Gonzales v. Google, Inc., 234 F.R.D. 674, 679–80 (N.D. Cal. 2006). Under Rule 26(b)(1),  
9       Parties may obtain discovery regarding any nonprivileged matter that is relevant to 
        any party’s claim or defense and proportional to the needs of the case, considering 
10       the importance of the issues at stake in the action, the amount in controversy, the 
        parties’  relative  access  to  relevant  information,  the  parties’  resources,  the 
11       importance of the discovery in resolving the issues, and whether the burden or 
        expense of the proposed discovery outweighs its likely benefit. Information within 
12       this scope of discovery need not be admissible in evidence to be discoverable. 

13  “Evidence is relevant if: (a) it has any tendency to make a fact more or less probable than it would 
14  be without the evidence; and (b) the fact is of consequence in determining the action.” Fed. R. 
15  Evid. 401.                                                                
16       Where a case involves both state and federal claims, “the federal law of privilege applies 
17  to both.” Robertson v. Catholic Cmty. Servs. of W. Wash., No. C19-1618-RSM, 2020 WL 1819842, 
18  at *3 (W.D. Wash. Apr. 10, 2020). Medical information regarding physical health care is not 
19  shielded  from  discovery  under  a  physician-patient  privilege  because  “[t]here  is  no  federal 
20  physician-patient privilege that bars a defendant from obtaining medical records.” Melendez v. 
21  Gulf Vessel Mgmt., No. C09-1100-MJP, 2010 WL 2650572, at *1 (W.D. Wash. July 1, 2010). 
22  Although confidential communications made to a psychiatrist or psychologist during the course of 
23  treatment are privileged under Federal Rule of Evidence 501, see Jaffee v. Redmond, 518 U.S. 1, 
24  15  (1996),  the  “privilege  may  be  waived  when  a  plaintiff  seeks  certain  emotional  distress 
1  damages.” Robertson, 2020 WL 1819842, at *4. Courts in this district generally find waiver when 
2  the plaintiff asserts “more than ‘garden-variety’ emotional distress.” Id.  
3  B.   Privacy Law Protections                                              
4       Mr. Ellis’s medical records are subject to protection under the Health Insurance Portability 

5  and Accountability Act of 1996 (“HIPAA”) and analogous state law. However, an entity subject 
6  to  HIPAA  “may  disclose  protected  health  information  in  the  course  of  any  judicial  or 
7  administrative proceeding . . . [i]n response to an order of a court or administrative tribunal, 
8  provided  that  the  covered  entity  discloses  only  the  protected  health  information  expressly 
9  authorized  by  such  order[.]”  45  C.F.R.  § 164.512(e)(1)(i);4  see  also  Wash.  Rev.  Code 
10  § 70.02.230(2)(p) (mental health treatment records can be disclosed pursuant to a court order); 
11  Wash. Rev. Code § 70.48.100(2)(c) (records of a person “confined in jail” may be disclosed “[f]or 
12  use in court proceedings upon the written order of the court in which the proceedings are 
13  conducted”). The records can also be disclosed with proper authorization from patients or their 
14  representatives.  45  C.F.R.  §  164.508  (allowing  disclosure  with  authorization);  45  C.F.R. 

15  § 164.502(g)(1) (requiring entities to treat personal representatives as the “individual” at issue, 
16  subject to exceptions not applicable here); 34 C.F.R. § 361.38(c) (records can be released to an 
17  individual’s representative); see also Wash. Rev. Code § 70.02.030(1) (patient may authorize 
18  disclosure); Wash. Rev. Code § 70.02.140 (“A personal representative of a deceased patient may 
19  exercise all of the deceased patient’s rights under this chapter.”);      
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   4 The entity may also disclose the information in response to a subpoena if it receives satisfactory assurances that a 
24  protective order is in place. 45 C.F.R. § 164.512(e)(1)(ii)(B) and (e)(1)(v). 
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12                                     Here, although the providers had a chance to 
13  respond to the subpoenas, they have not had an opportunity to file a written response with the 
14  Court.                                                                    

15       If Ms. Carter-Mixon provides consent for access Mr. Ellis’s records as set forth below, a 
16  court order will not be necessary. Therefore, the Court defers the motion as to any provider subject 
17  to              : if consent is obtained, the Court will order the motion moot as to such 
18  providers. If consent is not obtained, the Court will provide an opportunity for the providers to 
19  respond before ruling on this portion of the motion.                      
20  C.   Unnamed Health Care Providers                                        
21        Officer Rankine requests an order that commands additional unnamed medical providers 
22  to produce Mr. Ellis’s “medical, mental health, and/or treatment records upon issuance of any 
23  subpoena in this matter when this order is attached to said subpoena.” Dkt. No. 64-1 at 2. The 

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1  Court denies that request without prejudice because it cannot be evaluated without knowing the 
2  nature of the providers’ services to Mr. Ellis or the types of records they might hold. 
3  D.   Relevance and Proportionality                                        
4       Officer Rankine has largely established the relevance and proportionality of the records he 

5  seeks. However, he has not satisfactorily established the relevance of Mr. Ellis’s billing records as 
6  requested in the subpoenas. See, e.g., Dkt. No. 65-8 at 27. Presumably, any issue for which Mr. 
7  Ellis or a third-party payor was billed would also be reflected in the medical records, and there is 
8  no suggestion that Plaintiffs are seeking to recoup the cost of past medical bills as part of their 
9  damages in this case. Because the relevance of the providers’ billing records has not been 
10  established, they will not be compelled at this time.                     
11       In contrast, the other medical records requested by Officer Rankine are relevant to this 
12  case. Plaintiffs argue that absent Defendants’ actions, Mr. Ellis’s death would not have occurred. 
13  Dkt. No. 22 at 28–29. Defendants counter that Mr. Ellis’s own actions caused or contributed to his 
14  death. Dkt. No. 23 at 21; Dkt. No. 29 at 18–19; Dkt. No. 48 at 22; Dkt. No. 49 at 21–22; Dkt. No. 

15  50 at 19. They also assert that his health and   history, including   and 
16  related conditions, is “essential to properly evaluate the underlying facts of the incident, his cause 
17  of  death,  the  projected  quality  and  duration  of  his  life  had  he  lived,  his  relationship  with 
18  beneficiaries, his likely future earnings, and other general and specific damages issues.” See Dkt. 
19  No. 64 at 2–5, 11.                                                        
20       The cause of and potential contributing factors to Mr. Ellis’s death are squarely at issue in 
21  this case, and his medical records are relevant to whether pre-existing conditions caused or 
22  contributed to his death. The records are also relevant to damages. Ms. Carter brings a claim for 
23  the loss of the “companionship and society” of her son. Dkt. No. 22 at 28. Plaintiffs also assert that 

24  Mr. Ellis was 33 years old when he died, and “[b]ased on his life expectancy it is expected that he 
1  would have lived for several decades if his life had not been abruptly cut short by the Defendants.” 
2  Id. at 29. They seek damages for his lost earnings and lost earning capacity. Id. at 30. Plaintiffs 
3  acknowledge that Officer Rankine has sought to compel records from eight providers, see Dkt. 
4  No. 66 at 5, and they concede that “some of Manuel’s medical records could be relevant and 

5  discoverable in this case,” id. at 4 (emphasis in original). However, they argue that the Court should 
6  not compel production because Officer Rankine already has some of those records. Id. at 4. This 
7  argument has no basis in law. Plaintiffs’ subjective determination that Defendants have obtained 
8  sufficient documentation does not preclude Defendants from seeking to discover other relevant 
9  records, particularly since Defendants cannot depose Mr. Ellis regarding his medical issues. 
10  Because Mr. Ellis’s life expectancy, earning capacity, and relationship with his family could have 
11  been affected by his medical conditions, his medical records are relevant.  
12       Furthermore, doctor-patient privilege does not bar disclosure of these  records.  First, 
13  because “[t]here is no federal physician-patient privilege that bars a defendant from obtaining 
14  medical records,” Defendants are entitled to access the medical records of physicians who treated 

15  Mr.  Ellis.  Melendez,  2010  WL  2650572,  at  *1.  Second,  with  respect  to  the 
16  psychologist/psychiatrist-patient privilege, Plaintiffs have placed Mr. Ellis’s mental health history 
17  at issue by asserting damages for lost enjoyment of life, loss of consortium, and “more than garden-
18  variety” emotional distress as a result of Defendants’ actions. See, e.g., Dkt. No. 22 at 29–30 
19  (alleging among other things that “Manuel experienced unthinkable pain, suffering, and fear prior 
20  to death,” that “Manuel suffered for an extended period of time before he passed away,” and that 
21  Defendants’ actions resulted in injury to Ms.  Carter’s parent-child relationship and loss of 
22  enjoyment of life). Mr. Ellis’s mental health records will likely shed light on his relationship with 
23  his family and his emotional response to altercations with police in the past. Therefore, the Court 

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1  finds that the psychologist/psychiatrist-patient privilege has been waived. See, e.g., Robertson, 
2  2020 WL 1819842, at *4.                                                   
3       The  Court  must  also  consider  the  proportionality  and  appropriate  scope  of  Officer 
4  Rankine’s request. In evaluating proportionality, courts must consider “the importance of the 

5  issues at stake in the action, the amount in controversy, the parties’ relative access to relevant 
6  information, the parties’ resources, the importance of the discovery in resolving the issues, and 
7  whether the burden or expense of the proposed discovery outweighs its likely benefit.”  Fed. R. 
8  Civ. P. 26(b)(1); see also Uhler v. Van Cleave, No. C16-1278-RSM, 2017 WL 553276, at *5 (W.D. 
9  Wash. Feb. 10, 2017). As set forth above, Ms. Carter-Mixon, as personal representative, could 
10  access the medical information herself through an authorization and request, whereas Defendants 
11  cannot access the information absent Ms. Carter-Mixon’s authorization or a Court order. Plaintiffs 
12  are seeking “immense damages” in this case, Dkt. No. 22 at 29, and the Court finds that the burden 
13  and expense of production is not disproportionate to the needs of the case.  
14       With respect to the temporal scope of the discovery, Plaintiffs suggest that the records 

15  should be narrowed to the two-year period before Mr. Ellis’s death. Dkt. No. 66 at 7. Officer 
16  Rankine requests records that span ten years prior to Mr. Ellis’s death. The Court finds that Officer 
17  Rankine’s request is well-supported; the medical information available at this point suggests that 
18  events and issues impacting Mr. Ellis’s mental and physical health date back at least ten years. 
19  See, e.g., Dkt. No. 65-8 at 23 (noting that Mr. Ellis                     
20                          ); accord Melendez, 2010 WL 2650572, at *1–2 (compelling 
21  plaintiff to provide a medical release allowing defendant to obtain his medical records for the past 
22  10 years in a case involving alleged physical injuries sustained during employment on defendant’s 
23  boat; noting that the defendant’s “request for medical information from only the last ten years 

24  negates Melendez’s concerns about handing over a ‘lifetime of medical history’ that may not be 
1  wholly relevant.”). It is reasonable to anticipate that any condition that could have impacted Mr. 
2  Ellis’s life expectancy, earning capacity, and/or cause of death would appear in medical records 
3  during the 10 years prior to his death. Accordingly, the Court requires providers to submit records 
4  for Mr. Ellis dated between March 4, 2010 through March 4, 2020, the date of his death.  

5  E.   Authorization to Release Records                                     
6       During the telephone conference, the Court asked Ms. Carter-Mixon’s counsel if his client 
7  would sign an authorization for Defendants to obtain Mr. Ellis’s medical records if the Court 
8  limited the scope to a 10-year period for all facilities as it has done above. Counsel responded that 
9  Ms. Carter-Mixon would sign such an authorization.5 Based on that representation and the practice 
10  in this district of requiring parties to sign releases to obtain records,6 the Court orders Ms. Carter-
11  Mixon to sign an authorization allowing Defendants to obtain Mr. Ellis’s medical records from the 
12  providers listed in this order for use in this case.                      
13       The parties shall file a joint status report within 10 days of the date of this Order advising 
14  the Court that the authorization was signed. If there is any issue with obtaining the authorization, 

15  the parties must alert the Court in their joint status report. If an authorization cannot be obtained, 
16  the Court will issue a further order providing entities subject to   notice and an 
17  opportunity to respond.                                                   
18                          III.  CONCLUSION                                  
19       For the foregoing reasons, the Court GRANTS in part, DENIES in part, and DEFERS in 
20  part Officer Rankine’s telephonic motion to compel. Within 30 days of the date of this order, any 
21  of the following providers that are not subject to   shall provide all medical, 
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   5 The “collegial practice of [signing stipulations for records releases] is fairly routine in this district.” Robertson, 2020 
23  WL 1819842, at *7 n.7 (cleaned up) (brackets in original).                
   6 See Putterman v. Supreme Chain Logistics, Ltd., No. C18-376-RSM, 2018 WL 6179325, at *3 (W.D. Wash. Nov. 
24  27, 2018) (collecting cases).                                             
1  mental health, and/or treatment records dated March 3, 2010 through March 3, 2020 for Manuel 
2  E. Ellis, DOB 08/28/1986:7                                                
3         a.  Washington State-Department of Social and Health Services      
4            1949 State St., Tacoma, WA 98405                                

5         b.  Pierce County Sheriff’s Department-Corrections Jail            
6            910 Tacoma Avenue S, Tacoma, WA 98402                           
7         c.  Comprehensive Life Resources                                   
8            1305 Tacoma Avenue S, Tacoma, WA 98402                          
9         d.  Sea Mar Rehabilitation                                         
10            1415 Center Street, Tacoma, WA 98409                            
11         e.  Greater Lakes Mental Healthcare                                
12            9330 59th Ave SW, Lakewood, WA 98499                            
13         f.  Fairfax Hospital                                               
14            10200 NE 132nd St., Kirkland, WA 98034                          

15         g.                                                                 
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17         h.                                                                 
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19       The Court defers the motion as to any of the above-listed entities that are subject to   
20              , including but not limited to Sea Mar Rehabilitation and Greater Lakes Mental 
21  Healthcare.                                                               
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24  7 The Court has not redacted Mr. Ellis’s birthdate because he is deceased. LCR 5.2(a)(1).  
1       Any individual receiving Mr. Ellis’s medical or treatment records must treat them in 
2  accordance with the Stipulated Protective Order, Dkt. No. 63, and any applicable laws and rules 
3  regarding such records.                                                   
4       The Clerk of the Court is directed to seal this Order given the sensitive nature of the 

5  information therein. LCR 5.2(a). The Court will file a redacted copy of this Order and provide 
6  unsealed copies to the parties. By 5:00 p.m. on September 23, 2022, the parties are ordered to file 
7  a sealed joint motion under Local Civil Rule 5(g) identifying (1) any documents in the record that 
8  should be sealed and/or redacted in accordance with the Protective Order, applicable law, and the 
9  Local Rules, including but not limited to Local Civil Rules 5(g) and 5.2, and (2) any disagreements 
10  among the parties regarding such sealing/redaction. Any proposed redacted document must be 
11  filed under seal as attachments to the motion. Defendant Rankine’s counsel is reminded to exercise 
12  care in protecting sensitive information, and further violations of the protective order, the Local 
13  Rules, and/or applicable privacy rules may result in the imposition of sanctions.8   
14       Dated this 20th day of September, 2022.                              

15                                     A                                      
16                                     Lauren King                            
                                      United States District Judge           
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   8 Even after Officer Rankine was notified that his prior filing improperly included the birth dates of third parties, Dkt. 
24  No. 66 at 7, he did not remedy the problem by seeking to have the document sealed and filing a redacted copy. 

Case Information

Court
W.D. Wash.
Decision Date
September 20, 2022
Status
Precedential