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Medical Ctr. Inc. v. Bowden

The trial court abused its discretion in granting a motion to compel the hospital to produce its pricing agreements with health insurance companies and other information related to its charges for insured and uninsured patients, as the information was not relevant to the uninsured patient's allegation that the hospital's charges for her treatment were unreasonable.

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The Medical Center, Inc. “TMC” filed a hospital lien to recover the costs of providing emergency medical treatment to Danielle Bowden, an uninsured patient, for injuries she sustained in an automobile accident. When a dispute arose regarding satisfaction of the lien from insurance proceeds, the insurance company filed an interpleader action. Bowden counterclaimed against TMC, alleging that the hospital’s charges were unreasonable because it overcharges uninsured patients. Bowden subsequently moved to compel TMC to produce its pricing agreements with health insurance companies and other information related to its charges of insured and uninsured patients. The trial court granted Bowden’s motion to compel and issued a certificate of immediate review. We granted TMC’s application for interlocutory review, and on appeal TMC contends that the ordered discovery is not relevant nor reasonably calculated to lead to admissible evidence and encompasses confidential and proprietary information. This Court finds that the discovery Bowden seeks is not relevant to her claim that TMC’s medical charges for her treatment were unreasonable and we reverse the trial court’s order.

We review a trial court’s ruling on a motion to compel discovery for an abuse of discretion. Lovell v. Ga. Trust Bank, 318 Ga. App. 860, 862 1 734 SE2d 847 2012.

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