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A California appeals court has ruled in favor of a hospital that was sued after a computer containing an index of over 500,000 patients’ names and personal information was stolen, saying those profiles were not connected to medical histories.
The 4th Appellate District Division 2 of the Court of Appeal of the State of California on Wednesday overturned a ruling from Judge Harold W. Hopp of the Superior Court of Riverside County that dismissed a request for summary judgment from the Eisenhower Medical Center of Rancho Mirage, California.
The plaintiffs, including Carmen Malanche, originally filed a putative class action against Eisenhower Medical Center for breach of patient confidentiality under California’s Confidentiality of Medical Information Act.
In overturning the lower court’s ruling, the Court of Appeal stated that the hospital was not liable under the CMIA. The three-judge panel said that while information on the stolen computer included each person’s name, medical record number, age, date of birth and the last four digits of the person’s Social Security number, Eisenhower Medical Center was not liable because that information was not coupled with more complete information about the person’s medical history and course of treatment.
“Plaintiffs primarily argued that the mere fact that a person’s name is on the index reveals that he or she was a patient and, thus, there has been a release of medical history,” the ruling states. “In sum, we conclude that under the CMIA, a prohibited release by a health care provider must include more than individually identifiable information but must also include information relating to medical history, mental or physical condition, or treatment of the individual.”