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

Under South Dakota law and practice, there really are no limitations on a defendant’s ability to obtain a plaintiff’s complete medical history, both pre- and post-incident. The discovery rules are broadly interpreted under South Dakota law and even if the Plaintiff refuses to produce all medical records or to sign an appropriate medical authorization, the service of a subpoena will typically result in the production of all of plaintiff’s medical records. This leaves the plaintiff to try to convince the court to prevent or limit the admissibility of some or all of the evidence at the time of trial.