Roe v. Planned Parenthood Southwest Ohio Region

Jane Doe, a 14-year-old girl, had a sexual relationship with her 21-year-old soccer coach, John Haller. Jane fell pregnant, and Haller convinced Jane to get an abortion. Jane scheduled an abortion with Planned Parenthood Southwest Ohio Region (defendant). Because Jane was a minor, parental consent was required for her to obtain an abortion. Jane gave Planned Parenthood Haller’s number, and Haller pretended to be Jane’s father when Planned Parenthood called to obtain parental consent. Planned Parenthood gave Jane the required medical information packet, and Jane signed the required medical consent forms. After Jane received an abortion, Haller terminated their relationship. A teacher reported suspected child abuse after she overheard Jane talking about her sexual relationship with Haller. Haller was convicted of sexual battery. Jane’s parents, the Roes (plaintiffs), sued Planned Parenthood for punitive civil damages, arguing that Planned Parenthood failed to properly notify the Roes about Jane’s abortion and failed to report suspected child sexual abuse. The Roes’ claim was filed under Ohio’s original mandated-reporter statute. To support the Roes’ claim for punitive damages, the Roes demanded abuse reports and medical records for all abortions Planned Parenthood had performed on minors to determine whether Planned Parenthood consistently failed to report suspected child abuse. Planned Parenthood refused to comply, arguing that patient confidentiality barred disclosure. The trial court ordered the disclosure of redacted records, holding that the Roes’ need for discovery outweighed patient confidentiality. Planned Parenthood appealed, and the appellate court reversed, holding that the Roes were not statutorily entitled to punitive damages and that the Roes were not entitled to the disclosure of nonparties’ confidential medical records. The Roes appealed.