What is the test for accessing a patient's medical records?

"The constitutional right to privacy is not absolute. [Citations.] It may be outweighed by supervening concerns. [Citation.] The state has enough of an interest in discovering the truth in legal proceedings, that it may compel disclosure of confidential material. [Citation.] '[A]n individual's medical records may be relevant and material in the furtherance of this legitimate state purpose....' [Citation.] An 'intrusion upon constitutionally protected areas of privacy requires a "balancing of the juxtaposed rights, and the finding of a compelling state interest." [Citations.]' [Citation.]" (Palay v. Superior Court, supra, at p. 933, 22 Cal.Rptr.2d 839.)