Hartley v. University of Chicago Medical Center

CourtDistrict Court, N.D. Illinois
DecidedOctober 1, 2025
Docket1:22-cv-05891
StatusUnknown

This text of Hartley v. University of Chicago Medical Center (Hartley v. University of Chicago Medical Center) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hartley v. University of Chicago Medical Center, (N.D. Ill. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

SOPHIA HARTLEY, individually and on behalf of all others similarly situated,

Plaintiff, No. 22 CV 5891

v. Judge Georgia N. Alexakis

UNIVERSITY OF CHICAGO MEDICAL CENTER,

Defendant.

MEMORANDUM OPINION AND ORDER

This case is about the University of Chicago Medical Center’s alleged use of Meta’s data collection tools on its public website. Plaintiff Alyssa Hartley brought a putative class action alleging that UCMC violated the Electronic Communications Privacy Act by using those tools to intercept individually identifiable healthcare information with the purpose of sharing it with third-party Meta, the social media company, in violation of the Health Insurance Portability and Accountability Act. After surviving a motion to dismiss her second amended complaint and engaging in limited discovery, Hartley deleted over 50 paragraphs of allegations from her complaint. UCMC now moves to dismiss Hartley’s third amended complaint. UCMC also moves for summary judgment or to strike Hartley’s class claims. For the following reasons, the motion to dismiss is denied, and the motion for summary judgment or to strike Hartley’s class claims is denied in part and granted in part. I. Procedural History Hartley filed her original complaint in late 2022, [2], and her first amended complaint in early 2023, [33]. A court previously assigned to this case dismissed each claim in the first amended complaint on November 8, 2023. [52]. Two of the claims

were dismissed without prejudice, including the ECPA claim that now remains. [150] at ¶ 7; [52]. Five days later, on Hartley’s motion, the court clarified that the case was not terminated and set a deadline for Hartley to file a second amended complaint. [150] at ¶¶ 10, 11; [53]; [56]. On December 12, 2023, Hartley filed her second amended complaint, which contained over 90 paragraphs of new allegations, compare [61] with [33], including

“allegations that are specific to herself,” [75] at 5. Another court previously assigned to this case later ordered the parties to “conduct discovery on three threshold topics: (1) ownership and control of the four web properties [at issue in the second amended complaint]; (2) installation and operation of the Meta collection tools on the MyChart patient portal; and (3) Hartley’s interactions with and use of the web properties including her review and consent to UCMC’s Terms of Use.” [91] at 2. Through that limited discovery, Hartley learned that UCMC had never installed Meta’s data

collection tools on UCMC’s MyChart patient portal. [105] at 2. She accordingly deleted 32 paragraphs of allegations, compare [126] with [61], resulting in the third amended complaint that is now at issue, [126]. II. Motion to Dismiss A. Legal Standards A complaint must contain “a short and plain statement” showing that the plaintiff is entitled to relief. Fed. R. Civ. P. 8(a)(2). A motion to dismiss under Rule

12(b)(6) challenges the sufficiency of the complaint, not its merits. See Fed. R. Civ. P. 12(b)(6); Gibson v. City of Chicago, 910 F.2d 1510, 1520 (7th Cir. 1990). To survive a Rule 12(b)(6) motion, the plaintiff need only allege facts that “allow[] the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). At this stage, the Court assumes that the facts alleged in the complaint are true and draws all reasonable inferences from those facts in the plaintiff’s favor. See Tobey v. Chibucos, 890 F.3d 634, 645 (7th

Cir. 2018). However, “[a] pleading that offers ‘labels and conclusions’ or ‘a formulaic recitation of the elements of a cause of action will not do.’” Ashcroft, 556 U.S. at 678 (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007)). Similarly, a complaint that “tenders ‘naked assertion[s]’ devoid of ‘further factual enhancement’” will not survive a motion to dismiss. Id. B. Allegations The defendant, UCMC, operates a non-profit hospital network and maintains

a public website (www.uchicagomedicine.org) for the purpose of communicating with its patients. [126] at ¶¶ 4, 142. Patients are encouraged to use the website to communicate with hospital staff. Id. However, unbeknownst to a patient using the website, UCMC deploys third-party computer code from Meta, id. at ¶¶ 56–64, to “capture both the ‘characteristics’ of an individual patient’s communications with the UCMC Website (i.e., their IP addresses, Facebook IDs, cookie identifiers, device identifiers and account numbers) and the ‘content’ of these communications (i.e., the URLs, buttons, pages, and tabs they click on and view),” id. at ¶ 69. Every time a

patient clicks on a page within UCMC’s public website, these collection tools link the patient’s identity to the communication and transmit the data to Meta to analyze it for the commercial use of both Meta and UCMC. Id. at ¶¶ 73–74. The plaintiff, Hartley, has been a UCMC patient since 2018, and, since then, has used UCMC’s public website to schedule appointments, request information on specific medical services, and research providers. Id. at ¶ 143. Specifically, she used the website’s “find-a-physician” page to find a primary care physician, id. at ¶ 144,

and used the website to access the login page for the MyChart patient portal, id. at ¶ 146. Through these website interactions, UCMC used the Meta collection tools to intercept information about “her status as a UCMC patient, the dates and times she logged-in to the MyChart [sic], and the webpages that she clicked and viewed related to her medical providers, conditions, and treatments.” Id. Based on these allegations, in her third amended complaint, Hartley asserts a

single claim, a violation of the ECPA, 18 U.S.C. 2510 et seq. [126] at ¶ 163. C. Analysis The ECPA imposes criminal and civil liability on persons who “intentionally intercept … any wire, oral, or electronic communication.” 18 U.S.C. § 2511(1)(a), (4); 18 U.S.C. § 2520. A person is not liable, however, for intercepting a communication to which it is a party, unless it does so “for the purpose of committing any criminal or tortious act in violation of the Constitution or laws of the United States or of any State.” 18 U.S.C. § 2511(2)(d). The parties do not dispute that UCMC was a party to any communications that

it allegedly intercepted. See [146] at 6. Hartley’s ECPA claim thus can advance only if she plausibly alleges that any interceptions were “for the purpose of committing a criminal or tortious act,” 18 U.S.C. § 2511(2)(d), such as the disclosure of individually identifiable health information in violation of HIPAA. HIPAA makes it a crime to “knowingly … disclos[e] individually identifiable health information to another person.” See 42 U.S.C. § 1320d-6(a)(3).

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