Gatlin v. Goodman

CourtDistrict Court, W.D. Arkansas
DecidedSeptember 6, 2019
Docket3:19-cv-03052
StatusUnknown

This text of Gatlin v. Goodman (Gatlin v. Goodman) is published on Counsel Stack Legal Research, covering District Court, W.D. Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gatlin v. Goodman, (W.D. Ark. 2019).

Opinion

IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF ARKANSAS HARRISON DIVISION PERRY JOE GATLIN PLAINTIFF □ V. CASE NO. 3:19-CV-03052 PROSECUTOR DEVON GOODMAN; JAIL ADMINISTRATOR JASON DAY; CORPORAL JARED POINTER; CORPORAL WADE; and JAILER HEATH HUDSON DEFENDANTS OPINION AND ORDER Perry Joe Gatlin (“Gatlin”), currently an inmate of the Boone County Detention Center (“BCDC”), has filed a civil rights action under 42 U.S.C. § 1983. He proceeds pro se and has sought leave to proceed in forma pauperis.

Gatlin names as Defendants Prosecuting Attorney Devon Goodman (“Goodman”), Jail Administrator Jason Day (“Day”), Corporal Jared Pointer (“Pointer”), Corporal Wade (“Wade”), and Jailer Heath Hudson (“Hudson”). Gatlin has sued the Defendants in both their individual and official capacities. The case is before the Court for preservice screening under the provisions of the Prison Litigation Reform Act (“PLRA”). Pursuant to 28 U.S.C. § 1915A, the Court has the obligation to screen any complaint in which a prisoner seeks redress from a governmental entity or officer or employee of a governmental entity. 28 U.S.C. § 1915(e)(2). I. BACKGROUND According to the allegations of the Complaint and Supplement (Docs. 2, 3), on April 14, 2019, Pointer “got ahold of’ medical records concerning Gatlin’s infant daughter. The

jailers then discussed the records and passed them around prior to faxing them to Goodman, the prosecutor in a case against Gatlin. According to Gatlin, Pointer thought it was “a joke and shared [the records] with not only his shift but the next shift.” The records were passed though Wade and Hudson as well as other officers. Once they were done passing the records around, Gatlin alleges that Wade, who discussed the records with shift commanders, including Day, gave Gatlin the medical records that had been intended “only” for him. Gatlin alleges that neither he nor his wife had signed a medical authorization form releasing the records. According to Gatlin, Goodman discussed the records with Derika Bell and Jamie Christman from the public defender’s office and also provided them with copies. Gatlin further alleges that Goodman “was heard in the courtroom discussing and making jokes, □ comments about my daughter[Js medical status.” Gatlin maintains that Goodman tried “to use the documents to further my incarceration due to a failure to appear in court.” Gatlin alleges that Defendants’ conduct in illegally obtaining, sharing, and using Gatlin’s daughter's medical records constitutes a violation of the Health Insurance Portability and Accountability Act (“HIPAA”) and a violation of his and his family’s constitutional right to privacy. As relief, Gatlin requests monetary damages as well as an order preventing Goodman from violating the medical privacy rights of inmates in the future. : li. LEGAL STANDARD Under the PLRA, the Court is obligated to screen the case prior to service of process being issued. The Court must dismiss a complaint, or any portion of it, if it

contains claims that: (1) are frivolous or malicious; (2) fail to state a claim upon which relief may be granted; or, (3) seek monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915(e)(2)(B)(i)-(iii). A claim is frivolous when it “lacks an arguable basis either in law or fact.” Neitzke v. Williams, 490 U.S. 319, 325 (1989). A claim fails to state a claim upon which relief may be granted if it does not allege “enough facts to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). “The essential function of a complaint under the Federal Rules of Civil Procedure is to give the opposing party fair notice of the nature and basis or grounds for a claim, and a general indication of the type of litigation involved.” Topchian v. JPMorgan Chase Bank, N.A., 760 F.3d 843, 848 (8th Cir. 2014) (internal quotation marks and citation omitted). However, the Court bears in mind that when “evaluating whether a pro se plaintiff has asserted sufficient facts to state a claim, we hold ‘a pro se complaint, however inartfully pleaded, . . . to less stringent standards than formal pleadings drafted by lawyers.” Jackson v. Nixon, 747 F.3d 537, 541 (8th Cir. 2014) (quoting Erickson v. Pardus, 551 U.S. 89, 94 (2007)). lll. DISCUSSION Section 1983 requires proof of two elements: (1) the conduct complained of must be committed by a person acting under color of state law, and (2) the conduct must deprive the plaintiff of rights or privileges secured by the Constitution or laws of the United States.

Gatlin’s first claim is for alleged violations of HIPAA. HIPAA does not expressly or impliedly create a private cause of action. Dodd v. Jones, 623 F.3d 563, 569 (8th Cir. 2010). Therefore, no plausible claim is stated. Gatlin’s second claim is that the handling of his daughter’s medical records invaded his constitutional right to privacy. The Supreme Court has recognized that “notions of substantive due process contained within the Fourteenth Amendment safeguard individuals from unwarranted governmental intrusions into their personal lives.” Whalen v. Roe, 429 U.S. 589, 598 n.23 (1977). This right was discussed by the Court of Appeals for the Eighth Circuit in the case of Cooksey v. Boyer, 289 F.3d 513 (8th Cir. 2002). In Cooksey, the Court described this limited right in the following terms: This safeguard includes protection of the individual interest in avoiding disclosure of personal matters, and has been characterized as the right to confidentiality. Not every disclosure of personal information will implicate the right to privacy, however, and the Supreme Court has cautioned against unwarranted expansion of the right[.] The personal rights found in the guarantee of personal privacy must be limited to those which are fundamental or implicit within the concept of ordered liberty. The Due Process Clause does not purport to supplant traditional tort law in laying down rules of conduct to regulate liabilities for injuries that attend living together in society. In accordance with these principles, we have consistently held that to violate the constitutional right of privacy the information disclosed must be either a shocking degradation or an egregious humiliation . . . to further some specific state interest, or a flagrant breach of a pledge of confidentiality which was instrumental in obtaining the personal information. A determination of whether a particular disclosure meets this exacting standard may include consideration of whether the person had a legitimate expectation that the information would remain confidential while in the state’s possession.

Id. at 515-16 (citations and internal quotation marks omitted). “When the information is inherently private, it is entitled to protection.” Eagle v. Morgan, 88 F.3d 620, 625 (8th Cir.

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Related

Whalen v. Roe
429 U.S. 589 (Supreme Court, 1977)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Dodd v. Jones
623 F.3d 563 (Eighth Circuit, 2010)
Randall Jackson v. Jay Nixon
747 F.3d 537 (Eighth Circuit, 2014)
Samvel Topchian v. JPMorgan Chase Bank, N.A.
760 F.3d 843 (Eighth Circuit, 2014)

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Gatlin v. Goodman, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gatlin-v-goodman-arwd-2019.