Report of Hospital’s Internal Investigation Of Discrimination Claim Held Privileged

A former hospital employee who alleged that he was subjected to employment discrimination, a hostile work environment and retaliation may not take discovery of an investigative report prepared by his employer in response to a pre-suit complaint, a federal court in Idaho said July 10 (Mendez v. Saint Alphonsus Reg’l Med. Ctr., Inc., , 2014 BL 191592, D. Idaho, 1:12-cv-00026-EJL-CWD, 7/10/14).

The U.S. District Court for the District of Idaho said the report, prepared by Saint Alphonsus Regional Medical Center Inc.'s employee relations manager, was protected by the attorney-client privilege and the work product doctrine.

The court ...