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Keywords

lawsuitdefendantliabilityfiduciarycorporationfiduciary dutybreach of fiduciary dutycommon law

defendantappealfiduciarycorporationfiduciary dutycommon law

Related Cases

Doe v. Guthrie Clinic, Ltd., 22 N.Y.3d 480, 5 N.E.3d 578, 982 N.Y.S.2d 431, 2014 N.Y. Slip Op. 00138

Facts

John Doe was treated for a sexually transmitted disease at the Guthrie Clinic Steuben. A nurse, who recognized him as a relative's boyfriend, accessed his medical records and disclosed his condition via text messages to her sister-in-law. After Doe complained, the nurse was fired, and the clinic acknowledged the unauthorized disclosure. Doe filed a lawsuit against the clinic and its affiliates, asserting multiple claims, including breach of fiduciary duty.

On July 1, 2010, “John Doe” was being treated for a sexually transmitted disease (STD) at the Guthrie Clinic Steuben, a private medical facility. A nurse employed by the Clinic recognized Doe as the boyfriend of her sister-in-law. The nurse accessed Doe's medical records and learned that he was being treated for the STD. While Doe was still awaiting treatment, she sent text messages to her sister-in-law informing her of Doe's condition.

Issue

Whether, under New York law, the common law right of action for breach of the fiduciary duty of confidentiality for the unauthorized disclosure of medical information may run directly against medical corporations, even when the employee responsible for the breach is not a physician and acts outside the scope of her employment.

Rule

A medical corporation's duty of safekeeping a patient's confidential medical information is limited to those risks that are reasonably foreseeable and to actions within the scope of employment.

Analysis

The court found that the nurse's actions were not foreseeable to the defendants and were outside the scope of her employment, as she acted for personal reasons unrelated to Doe's treatment. Therefore, the court concluded that the medical corporation could not be held vicariously liable for the nurse's unauthorized disclosure of confidential information.

The court explained that in his complaint Doe himself alleged that the nurse was motivated by purely personal reasons and “[t]hose reasons had ‘nothing to do with [Doe's] treatment and care’ ” (id. at 495–496, citing Doe complaint at ¶ 25). “As such,” the court held, the nurse's “actions cannot be imputed to the defendants on the basis of respondeat superior” (id. at 496).

Conclusion

The court answered the certified question in the negative, holding that a medical corporation is not liable for breaches of confidentiality by employees acting outside the scope of their employment.

Accordingly, the certified question should be answered in the negative.

Who won?

Guthrie Clinic Steuben prevailed in the case because the court determined that the nurse's actions were not foreseeable and outside the scope of her employment, thus absolving the medical corporation of liability.

The Court of Appeals, Pigott, J., held that medical corporation's duty of safekeeping patient's confidential medical information is limited to those risks that are reasonably foreseeable and to actions within scope of employment.

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