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Doe v. Medlantic Health Care Group, Inc.

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Citation. Doe v. Medlantic Health Care Group, Inc., 814 A.2d 939, 2003 D.C. App. LEXIS 2 (D.C. Jan. 16, 2003)

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?


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