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Doe v. Medlantic Health Care Group, Inc.

    Brief Fact Summary. Doe (Plaintiff) brought suit against Medlantic Health Care Group, Inc. (Defendant) for negligent disclosure of his positive Human Immunodeficiency Virus (HIV) status, claiming invasion of privacy and breach of a confidential relationship.

    Synopsis of Rule of Law. The obligation of confidentiality that goes with the patient-provider relationship carries a stricter duty than that of a reasonable person to honor the trust and confidence created by the special relationship.

    Facts. Doe (Plaintiff) held two jobs, one with a federal agency and the other as a janitor for a company providing the State Department with cleaning services.  One of Plaintiff’s co-workers at the State Department, Tijuana Goldring, also worked at Washington Hospital Center (WHC), where Plaintiff was being treated for HIV.  Not long after his visit to the clinic, Plaintiff found out that his co-workers at the State Department knew of his illness and he was then extremely ridiculed because of it.  Once Plaintiff realized that Goldring was behind the rumors about his medical condition, he sued Goldring for invasion of privacy and sued Medlantic Health Care Group, Inc. (Defendant), the owner of WHC, for breach of confidential relationship.  Goldring was later dismissed from the suit, as the jury learned that Goldring’s disclosure was not within the scope of her employment at WHC.  However, the jury ruled in favor of Plaintiff against Defendant and awarded damages of $250,000 on the breach of confidence relationship claim.  But the trial judge found that Plaintiff’s claim was time barred by the relevant statute of limitations and granted a motion for judgment for defendant.  Plaintiff appealed.

    Issue. Does the obligation of confidentiality that goes with the patient-provider relationship carry a stricter duty than that of a reasonable person to honor the trust and confidence created by the special relationship?

    Held. (Ruiz, J.)  Yes.  The obligation of confidentiality that goes with the patient-provider relationship carries a stricter duty than that of a reasonable person to honor the trust and confidence created by the special relationship.  The tort of a breach of a confidential relationship consists of the “unconsented, unprivileged disclosure to a third party of nonpublic information that the defendant has learned within a confidential relationship.”  Sufficient evidence was presented at trial to allow the jury to find that Defendant failed to observe the “utmost caution” in preserving the confidentiality of Plaintiff’s medical records.  There was substantial evidence showing the routine failure of staff members to follow hospital privacy protocol and the distribution of private information without verifying the identity of the person requesting the information or the actual reason for their request.  There was enough casual evidence to establish Goldring’s link as the source of the unauthorized disclosure and of the hospital’s lapse in protecting the privacy of Defendant to support the verdict of the jury.  The judgment of the trial court is reversed and the case is remanded for reinstatement of the jury’s verdict.

    Discussion. This case is used by the casebook author to show the level of duty associated with the tort of breach of a confidential relationship.  This duty of care is equal to that of a fiduciary relationship.  A fiduciary duty carries with it a higher standard than simple negligence or the reasonable person standard.  A fiduciary must act with the highest degree of honesty, forthrightness, loyalty and reliability within the parameters of the special relationship to the client.  While the present case was not used for this purpose, it should be noted that the court of appeals reversed and remanded with directions that the trial judge reinstate the jury verdict based on the trial judge’s error regarding the granting of Defendant’s motion.  The appellate court applied a discovery rule to the statute of limitations and found that the cause of action accrued when the Plaintiff was deemed to be on inquiry notice, or “that notice which a plaintiff would have possessed after due investigation.”  The trial court erred when it failed to credit Plaintiff with the reasonable inferences that came from the evidence when the jury reasonably concluded that Plaintiff was not on notice until May 20, 1996, which means his claim was filed in time.  In deviating from the findings of the jury, the trial judge improperly invaded the territory of the fact-finding role of the jury.  The sufficiency of the evidence was discussed in relation to supporting the merits of Plaintiff’s claim, but it did not influence the procedural context to order that the jury’s verdict be reinstated.


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