Texas Supreme Court

R.k., M.d., Relator v. the Honorable Mario E. Ramirez, Jr., Respondent

December 22, 1994887 S.W.2d 836

Summary

The Texas Supreme Court held that the physician‑patient and mental‑health privileges are waived only when (1) the records sought are relevant to the patient’s condition and (2) that condition is a fact of legal significance to a party’s claim or defense, and it directed the trial court to vacate its blanket order and conduct a limited in‑camera review. Justice Enoch dissented, arguing that the plaintiffs’ pleadings do not rely on Dr. R.K.’s condition and that the privilege should remain intact.