What limitations exist, if any, on a defendant’s ability to obtain a plaintiff’s complete medical history, both pre and post incident?

Beyond the protection afforded by the psychologist-patient privilege and the psychiatric-patient privilege, there are no real limitations on a defendant’s ability to obtain the complete medical history, both pre and post incident, of a personal injury plaintiff in Alabama. There are certain procedural issues with regard to HIPAA or confidentiality orders. As for the two statutory privileges that could come into play, a patient has a privilege to prevent the disclosure of communications made for the purpose of diagnosis and treatment of the plaintiff’s mental or emotional condition as long as that diagnosis or treatment is sought from either a licensed psychologist or a licensed physician who is regularly engaged in the diagnosis and treatment of mental or emotional conditions. Alabama Code § 34-26-2 (1975).