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Criminal Procedure Keyed to Miller
George Tiller v. Michael Corrigan
Citation:
182 P.3d 719 (Kan. 2008)Facts
A grand jury issued subpoenas duces tecum in its investigation of alleged illegal abortions and other violations by Tiller (plaintiff), other medical professionals, and patients at Women’s Health Care Services, Inc. (WHCS). Judge Corrigan (defendant) signed the subpoenas duces tecum requesting copies of all health records of each patient who received an abortion at WHCS during a specified time period as well as the records of each patient who did not receive an abortion during that time period. The plaintiffs argued that the subpoenas for more than 2,000 records imposed an undue burden and violated patients’ privacy rights.
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