In Kates v. Doylestown Hospital, the Pennsylvania Superior Court, in a non-precedential decision, held back the Pennsylvania Peer Review Protection Act does not provide confidentiality protection for certain records, stating:

Peer review necessarily involves evaluating the quality of care provided by medical professionals or evaluating the qualifications of medical care providers. 0045cept for those

In Kentucky, common law president permits discovery of peer review documents. Ohio Rev. Code § 2305.252 protects peer review discovery.

In Saleba v. Schrand, the estate of a Kentucky resident sued an Ohio physician and Good Samaritan Hospital, located in Cincinnati, Ohio, in Kentucky based upon the results of medical services performed in Ohio. The Kentucky