Illinois Court on Workers’ Compensation Commission’s Authority to Subpoena Copies of Medical Records


The Appellate Court of Illinois, First District, recently addressed the issue of the proper scope of a subpeona duces tecum issued by the Workers’ Compensation Commission.

In Holtkamp Trucking Company v. Fletcher, M.D., one of the issues before the court was was whether the Illinois Workers’ Compensation had the authority to issue a subpoena duces tecum to a physician, wherein the subpoena required that the physician photocopy medical records for a fee and send the records to the employer of an employee who had filed an Illinois workers’ compensation claim.

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