Prior to 395, yes. I think 395 meant to do away with search warrants as a way to obtain medical records.
Often times a legislature will codify a court rule. They've probably always been obtainable via subpoena according to court rule. The law is just a codification of rules promulgated by the judiciary.
The subpoena clause of 395 was part of a larger statute devoted to medical privacy.
I believe it was intended to further protect privacy by giving the patient a chance to contest the release. A search warrant negates that opportunity.
The debate seems to be whether or not the prosecutor is required to follow Statute 395. It is a fact that he did not abide by it, agreed?
I think the better way to state it would be was the prosecutor even required to abide by it. He clearly acted under another provision of law - but to say he 'did not abide by it' implies some sort of wrong doing.