On August 14, 2008, the Second Division of the Illinois Appellate Court published its opinion in Anderson v. Rush-Copley Medical Center, Inc.  In Anderson, the plaintiff's wife died in the defendant's emergency room.  During discovery, the plaintiff requested to view medical journal articles reviewed by the peer-review committee, as well as the committee’s “action plan.”  The defendant argued the documents were privileged under the Illinois Medical Studies Act (the “Act”).  The court held that medical journals, while not prepared by the committee, were nonetheless privileged under the Act as a reflection of the committee’s internal review process.  With respect to the committee's action plan, the court held that the action plan also was privileged, because it was a summary of the issues discussed and risk reduction strategies, which may ultimately result in policy changes.  The court further stated that “the plain language of the Act protects from disclosure any recommendations made and internal conclusions reached by a peer-review committee, regardless whether they are implemented.”